Environmental Impact Statement

for the Ross ISR Project in Crook 

County, Wyoming

Supplement to the Generic 

Environmental Impact Statement 

for In-Situ Leach Uranium

Milling Facilities

Draft Report for Comment

Office of Federal and State Materials and 

Environmental Management Programs

NUREG-1910

Supplement 5
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Environmental Impact Statement

for the Ross ISR Project in Crook

County, Wyoming

Supplement to the Generic 

Environmental Impact Statement 

for In-Situ Leach Uranium

Milling Facilities

Draft Report for Comment

Manuscript Completed: February 2013

Date Published: March 2013

Office of Federal and State Materials and

 Environmental Management Programs

NUREG-1910

Supplement 5
COMMENTS ON DRAFT REPORT

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

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

Please specify the report number NUREG–1910, Supplement 5, in your comments, and send 

them by the end of the comment period specified in the Federal Register notice announcing 

the availability of this report to the following address:

Cindy Bladey, Chief

Rules, Announcements, and Directives Branch 

Division of Administrative Services

Office of Administration

Mail Stop: TWB-05-B10M

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

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

Johari Moore

Mail Stop T8F5

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

Phone: 301-415-7694

E-mail: Johari.Moore@nrc.gov

Please be aware that any comments that you submit to the NRC will be considered a public 

record and entered into the Agencywide Documents Access and Management System 

(ADAMS). Do not provide information you would not want to be publicly available. 
iii

1 ABSTRACT

2

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

4 of source and byproduct materials provided that facilities meet NRC regulatory requirements 

5 and will be operated in a manner that is protective of public health and safety and the 

6 environment. Under the NRC environmental-protection regulations in the Code of Federal 

7 Regulations (CFR), Title 10, Part 51, which implement the National Environmental Policy Act 

8 of 1969 (NEPA), issuance of a license to possess and use source and byproduct materials 

9 during uranium recovery and milling requires an environmental impact statement (EIS) or a 

10 supplement to an EIS (SEIS).

11

12 In May 2009, the NRC issued NUREG–1910, Generic Environmental Impact Statement

13 (GEIS) for In-Situ Leach Uranium Milling Facilities. In the GEIS, the NRC assessed the 

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

15 decommissioning of in situ recovery (ISR) facilities located in four specific geographic regions 

16 of the western U.S. As part of this assessment, the NRC determined which potential impacts 

17 would be essentially the same for all ISR facilities and which would result in varying levels of 

18 impacts for different facilities and would therefore require further site-specific information to 

19 determine potential impacts. The GEIS provides a starting point for the NRC’s NEPA 

20 analyses for site-specific license applications for new ISR facilities as well as for applications 

21 to amend or to renew existing ISR licenses.

22

23 By a letter dated January 4, 2011, Strata Energy Inc. (referred to herein as Strata or the 

24 “Applicant”) submitted a license application to the NRC for a new source and byproduct 

25 materials license for the proposed Ross Project. The Ross Project would be located in Crook 

26 County, Wyoming, which is in the Nebraska-South Dakota-Wyoming Uranium Milling Region 

27 identified in the GEIS. The NRC staff prepared this SEIS to evaluate the potential 

28 environmental impacts of the Applicant’s proposal to construct, operate, conduct aquifer 

29 restoration, and decommission an ISR facility at the Ross Project. This SEIS describes the 

30 environment that could be affected by the proposed Ross Project activities, estimates the 

31 potential environmental impacts resulting from the Proposed Action and two Alternatives, 

32 discusses the corresponding proposed mitigation measures, and describes the Applicant’s 

33 environmental-monitoring program. In conducting its analysis for this SEIS, the NRC staff 

34 evaluated site-specific data and information to determine whether the site characteristics and 

35 the Applicant’s proposed activities were consistent with those evaluated in the GEIS. The 

36 NRC staff then determined relevant sections, findings, and conclusions in the GEIS that 

37 could be incorporated by reference, and identified the areas that needed additional analysis. 

38 Based on its environmental review, the preliminary NRC staff recommendation is that, unless 

39 safety issues mandate otherwise, the source and byproduct materials license be issued as 

40 requested.

41

42 Paperwork Reduction Act Statement

43

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

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

46 collections were approved by the Office of Management and Budget (OMB), approval 

47 numbers 3150-0014, 3150-0020, 3150-0021, and 3150-0008.
iv

1 Public Protection Notification

2

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

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

5 a current valid OMB control number.

6

7 References

8

9 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51. “Environmental 

10 Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

11 Washington, DC: U.S. Government Printing Office.

12

13 NRC. NUREG–1910, “Generic Environmental Impact Statement for In-Situ Leach Uranium 

14 Milling Facilities.” Washington, DC: NRC. May 2009. Agencywide Documents Access and 

15 Management System (ADAMS) Accession Nos. ML091480244 and ML091480188. 
v

TABLE OF CONTENTS

Section Page

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

LIST OF FIGURES .............................................................................................................. xiii

LIST OF TABLES .................................................................................................................xv

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

ABBREVIATIONS/ACRONYMS......................................................................................... xxix

UNIT CONVERSIONS ....................................................................................................... xliii

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

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

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

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

1.3.1 BLM’s Purpose and Need................................................................. 1-3

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

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

1.4.2 Public Participation Activities............................................................ 1-5

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

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

1.4.5 Related NEPA Reviews and Other 

Related Documents.......................................................................... 1-6

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

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

1.6.1 NRC Licensing Process for the Ross Project................................... 1-8

1.6.2 Status of Permitting with other

Federal, Tribal, and State Agencies................................................. 1-8

1.7 Consultations ............................................................................................... 1-9

1.7.1 Endangered Species Act of 1973 Consultation................................. 1-9

1.7.2 National Historic Preservation Act 

of 1966 Consultation ........................................................................ 1-9

1.7.3 Coordination with Other Federal, Tribal,

State, and Local Agencies.............................................................. 1-12

1.7.3.1 Coordination with the Bureau of

Land Management ........................................................ 1-12

1.7.3.2 Interactions with Tribal

Governments ................................................................ 1-13

1.7.3.3 Coordination with National Park Service ....................... 1-15

1.7.3.4 Coordination with the Wyoming Department

of Environmental Quality ............................................... 1-15

1.7.3.5 Coordination with the Wyoming Game and

Fish Department ........................................................... 1-16

1.7.3.6 Coordination with the City of Moorcroft

First Responders........................................................... 1-16

1.7.3.7 Coordination with the Powder River Basin

Resource Council.......................................................... 1-16

1.7.3.8 Coordination with Localities........................................... 1-16
vi

TABLE OF CONTENTS

(Continued)

Section Page

1.8 Structure of the SEIS ................................................................................. 1-16

1.9 References ................................................................................................ 1-17

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

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

2.1.1 Alternative 1: Proposed Action ........................................................ 2-3

2.1.1.1 Ross Project Construction............................................. 2-12

2.1.1.2 Ross Project Operation ................................................. 2-26

2.1.1.3 Ross Project Aquifer Restoration .................................. 2-32

2.1.1.4 Ross Project Decommissioning..................................... 2-35

2.1.1.5 ISR Effluents and Waste Management.......................... 2-37

2.1.1.6 Transportation............................................................... 2-43

2.1.1.7 Financial Surety ............................................................ 2-43

2.1.2 Alternative 2: No Action................................................................. 2-44

2.1.3 Alternative 3: North Ross Project .................................................. 2-44

2.2 Alternatives Eliminated from Detailed Analysis ......................................... 2-46

2.2.1 Conventional Mining and Milling .................................................... 2-46

2.2.2 Alternate Lixiviant Chemistry ......................................................... 2-49

2.2.3 Alternate Waste Management Methodologies ............................... 2-50

2.3 Comparison of Predicted Environmental Impacts ...................................... 2-51

2.4 Preliminary Recommendation .................................................................... 2-51

2.5 References ................................................................................................ 2-53

3 DESCRIPTION OF AFFECTED ENVIRONMENT .................................................. 3-1

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

3.1.1 Relationship between the Proposed Project

and the GEIS.................................................................................... 3-1

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

3.2.1 Pasture-, Range-, and Croplands ..................................................... 3-3

3.2.2 Hunting and Recreation ................................................................... 3-3

3.2.3 Minerals and Energy ........................................................................ 3-4

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

3.4 Geology and Soils ....................................................................................... 3-8

3.4.1 Ross Project Geology ...................................................................... 3-9

3.4.1.1 Structural Geology .......................................................... 3-9

3.4.1.2 Stratigraphy................................................................... 3-12

3.4.2 Soils ............................................................................................... 3-14

3.4.3 Uranium Mineralization................................................................... 3-17

3.4.4 Seismology..................................................................................... 3-18

3.5 Water Resources ....................................................................................... 3-18

3.5.1 Surface Water ................................................................................ 3-20

3.5.2 Wetlands ........................................................................................ 3-29

3.5.3 Ground Water................................................................................. 3-30

3.6 Ecology...................................................................................................... 3-45

3.6.1 Terrestrial Species ......................................................................... 3-46
vii

TABLE OF CONTENTS

(Continued)

Section Page

3.6.1.1 Vegetation..................................................................... 3-46

3.6.1.2 Wildlife .......................................................................... 3-48

3.6.1.3 Reptiles, Amphibians, and Aquatic Species .................. 3-54

3.6.1.4 Protected Species......................................................... 3-55

3.7 Meteorology, Climatology, and Air Quality.................................................. 3-64

3.7.1 Meteorology ................................................................................... 3-64

3.7.2 Climatology .................................................................................... 3-68

3.7.3 Air Quality ..................................................................................... 3-68

3.7.3.1 Particulates .................................................................. 3-71

3.7.3.2 Gaseous Emissions ..................................................... 3-71

3.8 Noise ......................................................................................................... 3-72

3.9 Historical, Cultural, and Paleontological Resources .................................. 3-74

3.9.1 Cultural Context for the Ross Project Area ..................................... 3-75

3.9.1.1 Prehistoric Era .............................................................. 3-75

3.9.1.2 Protohistoric/Historic Periods ........................................ 3-77

3.9.1.3 Historic Era ................................................................... 3-78

3.9.2 Historical Resources ...................................................................... 3-80

3.9.3 Cultural Resources......................................................................... 3-81

3.9.3.1 Culturally Significant Locations ..................................... 3-81

3.9.3.2 Tribal Consultation ........................................................ 3-81

3.10 Visual and Scenic Resources..................................................................... 3-84

3.10.1 Regional Visual and Scenic Resources .......................................... 3-86

3.10.2 Ross Project Visual and Scenic Resources.................................... 3-88

3.11 Socioeconomics......................................................................................... 3-89

3.11.1 Demographics ................................................................................ 3-89

3.11.2 Income ........................................................................................... 3-92

3.11.3 Housing.......................................................................................... 3-93

3.11.4 Employment Structure.................................................................... 3-93

3.11.5 Finance .......................................................................................... 3-94

3.11.6 Education ....................................................................................... 3-94

3.11.7 Health and Social Services............................................................. 3-95

3.12 Public and Occupational Health and Safety ............................................... 3-96

3.12.1 Existing Site Conditions.................................................................. 3-96

3.12.2 Public and Occupational Health and Safety.................................. 3-107

3.12.2.1 Public Health and Safety............................................. 3-107

3.12.2.2 Occupational Health and Safety.................................. 3-108

3.13 Waste Management................................................................................. 3-109

3.13.1 Liquid Waste Disposal.................................................................. 3-109

3.13.2 Solid Waste Disposal.................................................................... 3-110

3.14 References .............................................................................................. 3-110

4 ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES............................. 4-1

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

4.2 Land-Use Impacts........................................................................................ 4-2

4.2.1 Alternative 1: Proposed Action ........................................................ 4-2
viii

TABLE OF CONTENTS

(Continued)

Section Page

4.2.1.1 Ross Project Construction............................................... 4-3

4.2.1.2 Ross Project Operation ................................................... 4-4

4.2.1.3 Ross Project Aquifer Restoration .................................... 4-5

4.2.1.4 Ross Project Decommissioning....................................... 4-5

4.2.2 Alternative 2: No Action................................................................... 4-5

4.2.3 Alternative 3: North Ross Project..................................................... 4-6

4.3 Transportation ............................................................................................... 4-6

4.3.1 Alternative 1: Proposed Action ........................................................ 4-7

4.3.1.1 Ross Project Construction............................................... 4-9

4.3.1.2 Ross Project Operation..................... .............. .........4-10

4.3.1.3 Ross Project Aquifer Restoration .................................. 4-13

4.3.1.4 Ross Project Decommissioning..................................... 4-13

4.3.2 Alternative 2: No Action ................................................................ 4-14

4.3.3 Alternative 3: North Ross Project................................................... 4-15

4.4 Geology and Soils...................................................................................... 4-15

4.4.1 Alternative 1: Proposed Action ...................................................... 4-15

4.4.1.1 Ross Project Construction ............................................ 4-15

4.4.1.2 Ross Project Operation ....................................... .........4-18

4.4.1.3 Ross Project Aquifer Restoration .................................. 4-21

4.4.1.4 Ross Project Decommissioning..................................... 4-22

4.4.2 Alternative 2: No Action................................................................. 4-23

4.4.3 Alternative 3: North Ross Project................................................... 4-23

4.5 Water Resources ....................................................................................... 4-24

4.5.1 Alternative 1: Proposed Action ...................................................... 4-24

4.5.1.1 Ross Project Construction............................................. 4-25

4.5.1.2 Ross Project Operation ................................................. 4-29

4.5.1.3 Ross Project Aquifer Restoration .................................. 4-38

4.5.1.4 Ross Project Decommissioning..................................... 4-41

4.5.2 Alternative 2: No Action................................................................. 4-42

4.5.3 Alternative 3: North Ross Project................................................... 4-43

4.5.3.1 North Ross Project Construction ................................... 4-44

4.5.3.2 North Ross Project Operation ....................................... 4-44

4.5.3.3 North Ross Project Aquifer Restoration......................... 4-45

4.5.3.4 North Ross Project Decommissioning ........................... 4-45

4.6 Ecology...................................................................................................... 4-45

4.6.1 Alternative 1: Proposed Action ...................................................... 4-45

4.6.1.1 Ross Project Construction............................................. 4-45

4.6.1.2 Ross Project Operation ................................................. 4-51

4.6.1.3 Ross Project Aquifer Restoration .................................. 4-54

4.6.1.4 Ross Project Decommissioning..................................... 4-54

4.6.2 Alternative 2: No Action................................................................. 4-55

4.6.3 Alternative 3: North Ross Project................................................... 4-55

4.7 Air Quality .................................................................................................. 4-56

4.7.1 Alternative 1: Proposed Action ......................................................4-57

4.7.1.1 Ross Project Construction.............................................4-57
ix

TABLE OF CONTENTS

(Continued)

Section Page

4.7.1.2 Ross Project Operation .................................................4-62

4.7.1.3 Ross Project Aquifer Restoration ..................................4-63

4.7.1.4 Ross Project Decommissioning..................................... 4-64

4.7.2 Alternative 2: No Action.................................................................4-64

4.7.3 Alternative 3: North Ross Project................................................... 4-64

4.8 Noise ......................................................................................................... 4-65

4.8.1 Alternative 1: Proposed Action ...................................................... 4-66

4.8.1.1 Ross Project Construction............................................. 4-66

4.8.1.2 Ross Project Operation ................................................. 4-68

4.8.1.3 Ross Project Aquifer Restoration .................................. 4-69

4.8.1.4 Ross Project Decommissioning..................................... 4-69

4.8.2 Alternative 2: No Action................................................................. 4-70

4.8.3 Alternative 3: North Ross Project................................................... 4-70

4.9 Historical, Cultural, and Paleontological Resources ................................... 4-71

4.9.1 Alternative 1: Proposed Action ...................................................... 4-71

4.9.1.1 Ross Project Construction............................................. 4-71

4.9.1.2 Ross Project Operation ................................................. 4-72

4.9.1.3 Ross Project Aquifer Restoration .................................. 4-72

4.9.1.4 Ross Project Decommissioning..................................... 4-73

4.9.2 Alternative 2: No Action................................................................. 4-73

4.9.3 Alternative 3: North Ross Project .................................................. 4-73

4.10 Visual and Scenic Resources..................................................................... 4-73

4.10.1 Alternative 1: Proposed Action ...................................................... 4-74

4.10.1.1 Ross Project Construction............................................. 4-74

4.10.1.2 Ross Project Operation ................................................. 4-76

4.10.1.3 Ross Project Aquifer Restoration .................................. 4-78

4.10.1.4 Ross Project Decommissioning .................................... 4-78

4.10.2 Alternative 2: No Action ................................................................ 4-79

4.10.3 Alternative 3: North Ross Project ................................................. 4-79

4.11 Socioeconomics ........................................................................................ 4-79

4.11.1 Alternative 1: Proposed Action ..................................................... 4-80

4.11.1.1 Ross Project Construction ............................................ 4-80

4.11.1.2 Ross Project Operation ...........................................4-83

4.11.1.3 Ross Project Aquifer Restoration ................................. 4-83

4.11.1.4 Ross Project Decommissioning .................................... 4-83

4.11.2 Alternative 2: No Action ................................................................ 4-84

4.11.3 Alternative 3: North Ross Project .................................................. 4-84

4.12 Environmental Justice ............................................................................... 4-84

4.12.1 Minority and Low-Income Population Analysis for

the Ross Project ............................................................................ 4-86

4.12.2 Alternative 1: Proposed Action ..................................................... 4-86

4.12.3 Alternative 2: No Action ................................................................ 4-86

4.12.4 Alternative 3: North Ross Project .................................................. 4-88

4.13 Public and Occupational Health and Safety .............................................. 4-88

4.13.1 Alternative 1: Proposed Action ..................................................... 4-88
x

TABLE OF CONTENTS

(Continued)

Section Page

4.13.1.1 Ross Project Construction ............................................................. 4-88

4.13.1.2 Ross Project Operation ................................................ 4-90

4.13.1.3 Ross Project Aquifer Restoration ................................. 4-97

4.13.1.4 Ross Project Decommissioning .................................... 4-97

4.13.2 Alternative 2: No Action ................................................................ 4-98

4.13.3 Alternative 3: North Ross Project .................................................. 4-98

4.14 Waste Management .................................................................................. 4-99

4.14.1 Alternative 1: Proposed Action ..................................................... 4-99

4.14.1.1 Ross Project Construction .......................................... 4-101

4.14.1.2 Ross Project Operation .............................................. 4-103

4.14.1.3 Ross Project Aquifer Restoration ............................... 4-104

4.14.1.4 Ross Project Decommissioning .................................. 4-105

4.14.2 Alternative 2: No Action .............................................................. 4-106

4.14.3 Alternative 3: North Ross Project ................................................ 4-107

4.15 References .............................................................................................. 4-107

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

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

5.2 Other Past, Present, and Reasonably Foreseeable Future Actions.............. 5-1

5.2.1 Actions ............................................................................................. 5-2

5.2.1.1 Uranium Recovery .......................................................... 5-2

5.2.1.2 Mining ............................................................................. 5-9

5.3 Cumulative Impacts Analysis ..................................................................... 5-13

5.3.1 EISs as Indicators of Past, Present, and Reasonable

Foreseeable Future Actions............................................................ 5-13

5.3.2 Methodology................................................................................... 5-13

5.4 Land Use ................................................................................................... 5-14

5.5 Transportation............................................................................................ 5-16

5.6 Geology and Soils...................................................................................... 5-17

5.7 Water Resources ....................................................................................... 5-19

5.7.1 Surface Water ................................................................................ 5-19

5.7.2 Ground Water................................................................................. 5-22

5.8 Ecology...................................................................................................... 5-27

5.8.1 Terrestrial Ecology ......................................................................... 5-27

5.8.1.1 Vegetation..................................................................... 5-28

5.8.1.2 Wildlife .......................................................................... 5-28

5.8.2 Aquatic Ecology.............................................................................. 5-29

5.8.3 Protected Species .......................................................................... 5-29

5.9 Air Quality .................................................................................................. 5-30

5.10 Global Climate Change and Greenhouse-Gas Emissions........................... 5-33

5.10.1 Global Climate Change .................................................................. 5-33

5.10.2 Greenhouse-Gas Emissions........................................................... 5-34

5.11 Noise ......................................................................................................... 5-37

5.12 Historical, Cultural, and Paleontological Resources ................................... 5-39

5.13 Visual and Scenic Resources .................................................................... 5-43
xi

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(Continued)

Section Page

5.14 Socioeconomics ........................................................................................ 5-44

5.15 Environmental Justice ............................................................................... 5-46

5.16 Public and Occupational Health and Safety .............................................. 5-46

5.17 Waste Management .................................................................................. 5-48

5.17.1 Liquid Wastes ................................................................................ 5-48

5.17.1.1 Disposal by Deep-Well Injection ................................... 5-48

5.17.1.2 Disposal by Other Methods .......................................... 5-49

5.17.2 Solid Wastes ................................................................................. 5-50

5.18 References ................................................................................................ 5-51

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

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

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

6.2.1 Airborne Radiation Monitoring .......................................................... 6-3

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

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

6.2.4 Surface Water Monitoring................................................................. 6-5

6.2.5 Groundwater Monitoring ................................................................... 6-5

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

6.3.1 Surface-Water-Quality Monitoring .................................................... 6-6

6.3.2 Ground-Water Quality Monitoring ..................................................... 6-7

6.3.2.1 Post-Licensing, Pre-Operational

Ground-Water Sampling and Water-Quality Analysis ...... 6-7

6.3.2.2 Operational Ground-Water Sampling

and Water-Quality Analysis ............................................. 6-8

6.3.3 Flow and Pressure Monitoring of Wellfields and Pipelines................ 6-9

6.4 Meteorological Monitoring............................................................................ 6-9

6.5 Ecological Monitoring................................................................................. 6-10

6.5.1 Vegetation Monitoring..................................................................... 6-10

6.5.2 Wildlife Monitoring .......................................................................... 6-10

6.5.2.1 Annual Reporting and Meetings .................................... 6-10

6.5.2.2 Annual Inventory and Monitoring................................... 6-11

6.5.2.3 Wildlife Species............................................................. 6-11

6.6 References ............................................................................................... 6-12

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

7.1 Proposed Action .......................................................................................... 7-1

7.1.1 Ross Project Benefits ....................................................................... 7-1

7.1.1.1 Employment and Income................................................. 7-1

7.1.1.2 Tax Revenues................................................................. 7-1

7.1.2 Ross Project Costs........................................................................... 7-2

7.1.2.1 Internal Costs.................................................................. 7-2

7.1.2.2 External Costs................................................................. 7-2

7.1.3 Findings and Conclusions ................................................................... 7-8

7.2 Alternative 2: No Action............................................................................... 7-8
xii

TABLE OF CONTENTS

(Continued)

Section Page

7.3 Alternative 3: North Ross Project ................................................................ 7-8

7.4 References .................................................................................................. 7-8

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

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

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

9.2 Attenuation Environmental Company Team................................................. 9-1

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

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

10.2 Tribal Government Officials ....................................................................... 10-1

10.3 State Agency Officials ............................................................................... 10-4

10.4 Local Agency Officials ............................................................................... 10-4

10.5 Other Organizations and Individuals ......................................................... 10-5

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

APPENDIX B: VISUAL IMPACTS ANALYSIS ..................................................................B-1
xiii

LIST OF FIGURES

Figure Page

1.1 Ross Project Location.............................................................................................. 1-2

2.1 Ross Project Within the Lance District..................................................................... 2-2

2.2 Potential Satellite Areas in the Lance District........................................................... 2.4

2.3 Nebraska-South Dakota-Wyoming Uranium Milling Region..................................... 2-5

2.4 Proposed Ross Project Facility and Wellfields......................................................... 2-6

2.5 General Layout of Proposed Ross Project Facility................................................... 2-7

2.6 Schedule for Potential Lance District Development ................................................. 2-8

2.7 Primary Components of a Ross Project Wellfield Module ...................................... 2-17

2.8 Proposed Well-Installation Method 1 for Ross Project Injection 

and Recovery Wells............................................................................................... 2-18

2.9 Proposed Well-Installation Method 2 for Ross Project Monitoring Wells ................ 2-19

2.10 Proposed Well-Installation Method 3 for Ross Project Monitoring Wells ................ 2-20

2.11 Alternative 3: North Ross Facility.......................................................................... 2-47

3.1 Current Land Use of Ross Project Area................................................................... 3-2

3.2 Oil and Gas Wells within Two Miles of Ross Project Area........................................ 3-5

3.3 Existing and Planned Uranium-Recovery Facilities.................................................. 3-6

3.4 Existing Transportation Network in Northeast Wyoming .......................................... 3-7

3.5 Generalized Cross Section of Black Hills Monocline in the Oshoto Area ............... 3-10

3.6 Surface Geology of Ross Project Area .................................................................. 3-11

3.7 Regional Stratigraphic Column of Area Containing the Lance District.................... 3-13

3.8 Soil Mapped Units at Ross Project Area................................................................ 3-16

3.9 Probability of Earthquake with Magnitude of 

Greater Than Equal to 6.5 in 50 years .................................................................. 3-19

3.10 Little Missouri River Basin and Surface-Water Gaging Stations ............................ 3-21

3.11 Surface-Water Features of Ross Project Area ...................................................... 3-22

3.12 Surface-Water Monitoring Stations at Ross Project Area ...................................... 3-24

3.13 Predicted 100-Year Flood Inundation Boundaries ................................................ 3-28

3.14 Stratigraphic and Hydrogeologic Units at Ross Project Area ................................. 3-32

3.15 Potentiometric Contours of Ground Water in Ore-Zone Aquifer............................. 3-35

3.16 Baseline Vegetation at Ross Project Area ............................................................. 3-47

3.17 Gillette Airport Wind Rose ..................................................................................... 3-66

3.18 Ross Project Area Wind Rose ............................................................................... 3-66

3.19 Regional Visual Resources Management Classifications....................................... 3-85

3.20 Roads, National Parks, National Monuments, 

and Forests in Vicinity of Ross Project Area .......................................................... 3-87

3.21 Viewshed Analysis of Ross Project Area ............................................................... 3-90

3.22 Light-Pollution Study Area ..................................................................................... 3-91

3.23 Soil Sampling Locations at Ross Project Area..................................................... 3-104

3.24 Air-Particulate Sampling Stations at Ross Project Area ....................................... 3-106

4.1 Ross Project Design Components to be Decommissioned

And Land Uses to be Restored ............................................................................... 4-8

5.1 Eighty-Kilometer- (Fifty-Mile-) Radius Area around Ross Project Area ................... 5-4
xiv

LIST OF FIGURES

(Continued)

Figure Page

6.1 Ross Project Meteorological and Baseline Radiological Monitoring

Locations ................................................................................................................6-4
xv

LIST OF TABLES

Table Page

1.1 ISL GEIS Range of Expected Impacts in the Nebraska-South DakotaWyoming Uranium Milling Region............................................................................ 1-4

1.2 Environmental Approvals for the Proposed Ross Project....................................... 1-10

2.1 Surface Ownership at Ross Project Area............................................................... 2-10

2.2 Permeate Water Quality ........................................................................................ 2-32

3.1 Distribution of Surface Ownership and Subsurface Mineral Ownership ................... 3-3

3.2 Traffic Volumes on Roads and Highways in the

Vicinity of Ross Project Area ................................................................................... 3-8

3.3 Soil Coverage and Characteristics for Ross Project Area ...................................... 3-15

3.4 Geologic Units, Stratigraphic Horizons, and

Hydrologic Units of Ross Project Area................................................................... 3-33

3.5 Ore-Zone Aquifer Hydrogeologic Characteristics................................................... 3-36

3.6 Average Concentrations of Major Cations and Anions in Ground Water 

from the Ore-Zone (OZ) Aquifer and Aquifers Above (SM & SA) 

and Below (DM) the Ore Zone............................................................................... 3-40

3.7 Summary of Water Quality of Ground Water from the 

Ore-Zone (OZ) Aquifer and Aquifers Above (SA & SM) and

Below (DM) the Ore Zone...................................................................................... 3-41

3.8 Water-Quality Standards Exceeded in Ground Water 

at Ross Project (Pre-Licensing Baseline)............................................................... 3-42

3.9 Historical Ground-Water Use within Three Kilometers 

[Two Miles] of Ross Project Area........................................................................... 3-45

3.10 Species Diversity by Vegetation Type at Ross Project Area .................................. 3-46

3.11 Wildlife Species Observed on or near Ross Project Area ...................................... 3-48

3.12 Summary of Sage-Grouse Activity in Oshoto and Cap’n Bob Leks........................ 3-57

3.13 Species of Concern in Crook County and at Ross Project Area............................. 3-58

3.14 Avian Species of Concern Observed at Ross Project Area.................................... 3-64

3.15 Average, Minimum, and Maximum Temperatures in Ross Project Vicinity............. 3-65

3.16 Statewide Mixing Heights for Dispersion Modeling ................................................ 3-67

3.17 National and Wyoming Ambient Air Quality Standards .......................................... 3-70

3.18 Historic and Cultural Properties Identified 

within the Ross Project Area.................................................................................. 3-83

3.19 Scenic-Quality Inventory and Evaluation ............................................................... 3-88

3.20 Populations in Crook County, Campbell County, and Wyoming............................. 3-92

3.21 Range of Analytical Results of Pre-Licensing Baseline Samples ........................... 3-99

4.1 Summary of Land Disturbance during Construction of Proposed Action ................. 4-3

4.2 Estimated Number of Workers and Traffic Volumes for Ross Project ..................... 4-7

4.3 Estimated Non-Production Water Use .................................................................. 4-25

4.4 Non-Radioactive Emissions Summary .................................................................. 4-60

4.5 Respective Noise Levels of Construction Equipment............................................. 4-66

4.6 Estimated Major Tax Revenues ............................................................................ 4-80
xvi

LIST OF TABLES

(Continued)

Table Page

4.7 Ross Project Area Race and Ethnicity Characteristics .......................................... 4-87

4.8 Ross Project Area Poverty and Income Characteristics ........................................ 4-88

4.9 Ross Project Waste Streams............................................................................... 4-100

5.1 Uranium-Recovery Projects within 80 Kilometers [50 Miles] 

of Ross Project Area ............................................................................................... 5-8

5.2 Active Coal Mines within 80 Kilometers [50 Miles] 

of Ross Project Area ............................................................................................. 5-10

5.3 Active Bentonite Mines within 80 Kilometers [50 Miles]

of Ross Project Area.............................................................................................. 5-11

5.4 Comparison of Baseline and Post-Restoration Water Quality at Nubeth................ 5-26

5.5 Comparison of Annual Mass of Carbon-Dioxide Emissions by Source .................. 5-35

5.6 Maximum Annual Greenhouse-Gas Emissions...................................................... 5-36

6.1 Summary of the Major Elements of the Ross Project

Operational Environmental Monitoring Program ...................................................... 6-2

8.1 Summary of Environmental Consequences of the 

Proposed Action and Alternatives ........................................................................... 8-2
DRAFT Executive Summary 

xvii

1 EXECUTIVE SUMMARY

2

3 BACKGROUND

4

5 By a letter dated January 4, 2011, Strata Energy Inc. (Strata or the “Applicant”) submitted an 

6 application to the U.S. Nuclear Regulatory Commission (NRC) for a new source and 

7 byproduct materials license for the proposed Ross Project, an in situ recovery (ISR) project to 

8 be located in Crook County, Wyoming. The proposed Ross Project includes a central 

9 processing plant (CPP) to produce yellowcake, corresponding injection and recovery wells, 

10 deep-disposal wells for liquid effluents, monitoring wells throughout the Ross Project area as 

11 well as other various infrastructure (e.g., pipelines, roads, and lighting). 

12

13 The Atomic Energy Act of 1954 (AEA), as amended by the Uranium Mill Tailings Radiation 

14 Control Act of 1978, authorizes the NRC to issue licenses for the possession and use of 

15 source material and byproduct material. The NRC must license facilities, including ISR 

16 operations, in accordance with NRC regulatory requirements. These requirements were 

17 developed to protect public health and safety from radiological hazards and to protect 

18 common defense and security. The NRC’s environmental protection regulations are found at 

19 Title 10 of the Code of Federal Regulations (CFR), Part 51 (10 CFR Part 51); these 

20 regulations implement the National Environmental Policy Act of 1969 (NEPA). 10 CFR Part

21 51 requires that the NRC prepare an environmental impact statement (EIS) or supplement to 

22 another EIS (SEIS) or a generic EIS (GEIS) for its issuance of a license to possess and use 

23 source and/or byproduct materials for uranium milling (see 10 CFR Part 51.20[b][8]). 

24

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

26 In-Situ Leach Uranium Milling Facilities. In this GEIS, the NRC assessed the potential 

27 environmental impacts of the construction, operation, aquifer restoration, and 

28 decommissioning of ISR facilities located in four specified geographic regions of the western 

29 U.S. The proposed Ross Project is located within the Nebraska-South Dakota-Wyoming 

30 Uranium Milling Region (NSDWUMR) identified in the GEIS. The GEIS provides a starting 

31 point for the NRC’s NEPA analyses for site-specific license applications for new ISR facilities. 

32 This Draft SEIS incorporates by reference information from the GEIS. This document also 

33 uses information from the Applicant’s license application and subsequent environmental 

34 report and its responses to the NRC’s requests for additional information as well as other 

35 publicly available sources of information.

36

37 This Draft SEIS includes the NRC staff’s analysis of the environmental impacts from the 

38 Proposed Action (i.e., for the NRC to license the Ross Project), the environmental impacts of 

39 two Alternatives to the Proposed Action (i.e., the “No-Action” Alternative and the “North Ross 

40 Project” Alternative), and the mitigation measures that are intended to either minimize or 

41 avoid adverse impacts. It also includes the NRC staff’s preliminary recommendation 

42 regarding the Proposed Action. 
DRAFT Executive Summary 

xviii

1 PURPOSE AND NEED OF THE PROPOSED ACTION 

2

3 The NRC regulates uranium milling, including the ISR process, under 10 CFR Part 40, 

4 Domestic Licensing of Source Material. The Applicant is seeking an NRC source and 

5 byproduct materials license to authorize commercial-scale in situ uranium recovery at the 

6 Ross Project area. The purpose and need for this Proposed Action is to provide an option 

7 that allows the Applicant to recover uranium and to produce yellowcake at the Ross Project 

8 area. Yellowcake is the uranium oxide product of the ISR uranium-milling process that is 

9 used to produce various products, including fuel for commercially operated nuclear power 

10 reactors.

11

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

13 are findings in the safety review required by the AEA, as amended, or findings in the NEPA 

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

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

16 a particular location. 

17

18 THE PROJECT AREA AND FACILITY

19

20 Strata’s Proposed Action, the Ross Project, would occupy 697 ha [1,721 ac] in the north half 

of the approximately 90-km2 [56-mi2 21 ] Lance District, where the Applicant is actively exploring 

22 for additional uranium reserves. Strata has also identified four other uranium-bearing areas 

23 that would extend the area of uranium recovery to the north with the Ross Amendment Area 

24 1 and to the south of the Lance District with the Kendrick, Richards, and Barber satellite 

25 facilities. These areas are not a component of the Proposed Action in this SEIS.

26

27 The Lance District is located on the western edge in the northwest corner of the NSDWUMR. 

28 It is situated between the Black Hills uplift to the east and the Powder River Basin to the 

29 west. Both of these regional features are described in the GEIS. The environment of the 

30 Proposed Action is described in Section 3 of this SEIS.

31

32 The Proposed Action includes the ISR facility itself and its wellfields. The ISR facility consists 

33 of the following:

34

35 ■ A CPP that houses the uranium- and vanadium-processing equipment, drying and 

36 packaging equipment, and water-treatment equipment;

37 ■ A chemical storage area as well as other storage, warehouse, maintenance, and 

38 administration buildings; and

39 ■ Two double-lined surface impoundments, a sediment impoundment, and five Class I 

40 deep-injection wells.

41

42 The Proposed Action includes the option of the Applicant operating the Ross Project facility 

43 beyond the life of the Project’s wellfields. The facility could be used to process uranium44 loaded resins from satellite projects within the Lance District operated by the Applicant, or 

45 from other offsite uranium recovery projects not operated by the Applicant (i.e., “toll milling”), 

46 or from offsite water-treatment operations. With that option, the life of the facility would be 

47 extended to 14 years or more. 
DRAFT Executive Summary 

xix

1 The Ross Project would also host 15 – 25 wellfield areas and would consist of a total of 1,400 

2 – 2,000 recovery and injection wells. The wellfield areas would be surrounded by a perimeter 

3 ring of monitoring wells.

4

5 THE IN SITU URANIUM RECOVERY PROCESS 

6

7 During the in situ uranium recovery process, an oxidant-charged solution, called a lixiviant, is 

8 injected into the ore-zone aquifer (or uranium “ore body”) through injection wells. The ore 

9 zone is that portion of the aquifer that has been permanently exempted by the U.S. 

10 Environmental Protection Agency (EPA) from requirements as an underground source of 

11 drinking water under the Safe Drinking Water Act. Typically, a lixiviant uses native 

12 groundwater (from the ore-zone aquifer itself), carbon dioxide, and sodium 

13 carbonate/bicarbonate, with an oxygen or hydrogen peroxide oxidant. As it circulates though 

14 the ore zone, the lixiviant oxidizes and dissolves the mineralized uranium, which is present in 

15 a reduced chemical state. The resulting uranium-rich solution, the “pregnant” lixiviant, is 

16 drawn to recovery wells by pumping, and then transferred to the CPP via a network of pipes 

17 buried just below the ground surface. At the CPP, the uranium is extracted from the solution 

18 using an ion exchange process. The resulting “barren” (uranium-depleted) solution is then 

19 recharged with the oxidant and re-injected to recover more uranium from the wellfield. 

20

21 During production, the uranium recovery solutions continually move through the aquifer from 

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

23 geometric patterns depending on the ore-body’s configuration, the aquifer’s permeability, and 

24 the operator’s selection based upon operational considerations. Wellfields are often 

25 designed in a five-spot or seven-spot pattern, with each recovery (i.e., production) well being 

26 located inside a ring of injection wells. Monitoring wells surround the wellfield pattern area, 

27 terminating in the ore-zone aquifer as well as in both the overlying and underlying aquifers. 

28 These monitoring wells are screened in appropriate stratigraphic horizons to detect lixiviant 

29 should it migrate out of the production, or ore, zone. The uranium that is recovered from the 

30 solution would be processed in the CPP to yellowcake. The yellowcake would be packaged 

31 into NRC-and U.S. Department of Transportation (USDOT)-approved 208-L [55-gal] steel 

32 drums, and trucked offsite to a licensed uranium-conversion facility. 

33

34 Once uranium recovery is complete, the ore-zone’s ground water is restored to NRC35 approved ground-water protection standards, which are protective of the surrounding ground 

36 waters. The facility is decommissioned according to an NRC-approved decommissioning 

37 plan and in accordance with NRC-approved standards. Once decommissioning is approved 

38 by the NRC, the site may be released for public use. 

39

40 THE ALTERNATIVES 

41

42 The NRC environmental review regulations in 10 CFR Part 51, which implement NEPA, 

43 require the NRC to consider reasonable alternatives, including the No-Action alternative, to a 

44 proposed action. The NRC staff considered a range of alternatives that would fulfill the 

45 underlying purpose and need for the Proposed Action. From this analysis, a set of 

46 reasonable alternatives was developed, and the impacts of the Proposed Action were 

47 compared to the impacts that would result if a given alternative were implemented. This 

48 SEIS evaluates the potential environmental impacts of the Proposed Action and two 
DRAFT Executive Summary 

xx

1 Alternatives, including the No-Action Alternative and the North Ross Project. Under the No2 Action Alternative, the Applicant would neither construct nor operate a uranium recovery 

3 facility or wellfields at the proposed Ross Project. In Alternative 3, the proposed Ross 

4 Project’s facility (i.e., the CPP, surface impoundments, and auxiliary structures) would be 

5 constructed at a site north of where it is proposed to be located in the Proposed Action, but 

6 the wellfields would remain in the same locations as in the Proposed Action. This alternative 

7 facility location would require additional, substantial earth-moving to construct the surface 

8 impoundments, but a containment barrier wall (CBW) (described later in this SEIS) would not 

9 be required. Alternatives considered and eliminated from detailed analysis include 

10 conventional mining and milling, conventional mining and heap leach processing, and 

11 alternate lixiviants. These alternatives were eliminated from detailed study because they 

12 either do not meet the purpose and need of the proposed Ross Project or would cause 

13 greater environmental impacts than the Proposed Action. 

14

15 SUMMARY OF THE ENVIRONMENTAL IMPACTS

16

17 This Draft SEIS includes the NRC staff’s analysis, which considers and weighs the 

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

19 decommissioning of an in situ uranium recovery facility at the proposed Ross Project area 

20 and the two Alternatives. This SEIS also describes mitigation measures for the reduction or 

21 avoidance of potential adverse impacts that either: 1) the Applicant has committed to in its 

22 NRC license application, 2) would be required under other State or Federal permits or 

23 processes, or 3) are additional measures that the NRC staff identified as having the potential 

24 to reduce environmental impacts, but the Applicant did not commit to in its license 

25 application. The SEIS uses the assessments and conclusions reached in the GEIS in 

26 combination with site-specific information to assess and categorize impacts.

27

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

29 potential environmental impacts is categorized as follows: 

30

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

32 neither destabilize nor noticeably alter any important attribute of the 

33 resource considered. 

34

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

36 destabilize, important attributes of the resource considered. 

37

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

39 destabilize important attributes of the resource considered. 

40

41 Table ExS.1 provides a summary of the NRC’s evaluation of the potential environmental 

42 impacts of the construction, operation, aquifer restoration, and decommissioning of the Ross 

43 Project, followed by a brief summary of impacts by environmental resource area and lifecycle 

44 phase. These potential impacts are more fully described in Section 4 of this SEIS, where the 

45 magnitude of impacts by phase of the Ross Project is provided for each resource area. 
xxi

Table ExS.1

Summary of Environmental Impacts

Resource Area

Alternative 1: Proposed Action

Alternative 2:

No-Action

Construction Operation

Aquifer 

Restoration Decommissioning

Land Use SMALL SMALL SMALL SMALL SMALL 

Transportation

SMALL

to MODERATE

to LARGE

With Mitigation:

SMALL to 

MODERATE

SMALL 

to MODERATE 

to LARGE

With Mitigation:

SMALL to 

MODERATE

SMALL to 

MODERATE SMALL to 

MODERATE

With Mitigation:

SMALL to MODERATE

SMALL 

Geology and Soils 

 Geology SMALL SMALL SMALL SMALL SMALL 

 Soils SMALL SMALL SMALL SMALL SMALL 

Water Resources

 Surface Water

Water Quantity SMALL SMALL SMALL SMALL SMALL 

Water Quality SMALL SMALL SMALL SMALL SMALL 

 Wetlands SMALL SMALL SMALL SMALL SMALL 

 Ground Water SMALL SMALL

to MODERATE

(See 

OZ Aquifer 

Below)

SMALL

to MODERATE

(See 

OZ Aquifer

Below)

SMALL SMALL 

Shallow Aquifers

Water Quantity SMALL SMALL SMALL SMALL SMALL 

Water Quality SMALL SMALL SMALL SMALL SMALL 
 

xxii

Table ExS.1

Summary of Environmental Impacts

Resource Area

Alternative 1: Proposed Action

Alternative 2:

No-ActionConstruction Operation

Aquifer 

Restoration Decommissioning

 Ground Water

(Continued)

Ore-Zone Aquifers

Water Quantity SMALL SMALL SMALL to 

MODERATE

(Short-Term 

Drawdown)

SMALL SMALL 

Water Quality SMALL SMALL

(Long-Term)

SMALL to 

MODERATE

(Excursion)

SMALL SMALL SMALL 

Deep Aquifers

Water Quantity SMALL SMALL SMALL SMALL SMALL 

Water Quality SMALL SMALL SMALL SMALL

Ecology SMALL 

 Vegetation SMALL SMALL SMALL SMALL

 Wildlife SMALL SMALL SMALL SMALL

 Aquatic SMALL SMALL SMALL SMALL

 Protected Species SMALL SMALL SMALL SMALL

Air Quality SMALL SMALL SMALL SMALL SMALL 

Noise

SMALL TO 

MODERATE

(Short Term)

SMALL TO 

MODERATE

(Short Term)

SMALL

SMALL TO 

MODERATE

(Short Term)

SMALL 

Historical, Cultural,

and Paleontological

Resources

SMALL to 

LARGE SMALL SMALL SMALL SMALL 
 

xxiii

Table ExS.1

Summary of Environmental Impacts

Resource Area

Alternative 1: Proposed Action

Alternative 2:

No-Action

Construction Operation

Aquifer 

Restoration Decommissioning

Visual and Scenic 

Resources

SMALL

(Long-Term)

MODERATE

(Short-Term)

(First Year)

(Nearest 

Residents)

SMALL SMALL SMALL SMALL 

Socioeconomics SMALL 

to MODERATE

(Taxes Paid

to Crook County)

SMALL 

to MODERATE

(Taxes Paid

to Crook County)

SMALL SMALL SMALL 

Environmental 

Justice

N/A

No Minority or

Low-Income

Groups

N/A

No Minority or

Low-Income 

Groups

N/A

No Minority or

Low-Income 

Groups

N/A

No Minority or

Low-Income 

Groups

N/A

No Minority or

Low-Income

Groups

Public and 

Occupational Health SMALL SMALL SMALL SMALL SMALL 

and Safety

Waste Management

 Liquid SMALL SMALL SMALL SMALL SMALL 

 Solid SMALL SMALL SMALL SMALL SMALL 
DRAFT Executive Summary

xxiv

1 THE IMPACTS BY RESOURCE AREA AND PROJECT PHASE 

2

3 Land Use 

4

5 Construction: Impacts would be SMALL. The Ross Project area comprises a total of 697 

ha [1,721 ac] in the north half of the approximately 90-km2 [56-mi2 6 ] Lance District. This area 

7 is currently used for livestock grazing, wildlife habitat, some agriculture, and some oil 

8 production. A total of 113 ha [280 ac] of land, which represents 16 percent of the Ross 

9 Project area, would be disturbed during the construction of a CPP, surface impoundments, 

10 and other auxiliary structures such as storage areas and parking lots. The wellfields would 

11 be sequentially developed over the Ross Project lifecycle. All disturbed areas would be 

12 fenced and, thus, somewhat limit grazing by livestock, access by wildlife, and recreational 

13 opportunities. 

14

15 Operation: Impacts would be SMALL. Land-use impacts during the operations phase would 

16 be similar to, or less than, those during the construction phase because the buildings, surface 

17 impoundments, and infrastructure would be in place. Areas where Ross Project uranium18 production activities would take place would remain fenced, somewhat limiting grazing and 

19 some crop production. No new facilities would be constructed that would result in additional 

20 land disturbance during operation, although well drilling would continue as the wellfields 

21 would be sequentially developed. 

22

23 Aquifer Restoration: Impacts would be SMALL. Land-use impacts would be similar to, or 

24 less than, those during the construction and operation phases. Wellfield access would 

25 continue to be restricted from other uses such as livestock grazing and crop production, as 

26 described for the Ross Project’s operation phase. No new facilities would be constructed that 

27 would result in additional land disturbance. 

28

29 Decommissioning: Impacts would be SMALL. Land-use impacts during the Proposed 

30 Action’s decommissioning as well as the site’s reclamation would temporarily increase due to 

31 the additional equipment that would be used for dismantling and removing Ross Project 

32 components such as the CPP, surface impoundments, and wellfields. In addition, the 

33 reclamation of the site would involve significant earth moving, land disturbance, and access 

34 restrictions. However, these short-term impacts would not be greater than those experienced 

35 during the Ross Project’s construction phase. At the end of the Ross Project’s 

36 decommissioning and site reclamation, the preconstruction land uses would be restored.

37

38 Transportation 

39

40 Construction: Impacts would be MODERATE TO LARGE on local and county roads, but 

41 would be SMALL on the Interstate-highway system of the U.S. With the identified mitigation 

42 measures, the transportation impacts on local and county roads would lessen and they would 

43 be MODERATE. The highest traffic volume resulting from the Ross Project would occur 

44 during its construction phase, because of the large workforce (200 workers) and frequent 

45 supply, building material, and equipment shipments. The increased traffic is expected to be 

46 400 passenger cars and 24 trucks per day, which, when compared to 2010 volumes, 

47 represents a traffic increase of approximately 400 percent on the New Haven Road south of 

48 the Ross Project area. This significant increase in traffic could result in more traffic accidents 

49 as well as potentially significant wear and tear on the road surfaces. 
DRAFT Executive Summary

xxv

1 Operation: Impacts would be SMALL to LARGE; however, with mitigation, the transportation 

2 impacts during the Ross Project’s operation would be SMALL to MODERATE. Impacts such 

3 as the local road’s deterioration would be less than during construction, because of a smaller 

4 workforce (i.e., approximately 60 workers); however, the traffic volume associated with facility 

5 and wellfield operation would still be double that of 2010. The effective mitigation measures 

6 taken during the construction phase would continue through the operation phase.

7

8 Aquifer Restoration: Impacts would be MODERATE, and with the mitigation measures that 

9 would be implemented throughout the Ross Project’s lifecycle, the transportation impacts of 

10 aquifer restoration would also be MODERATE. Transportation impacts during this phase 

11 would be similar to those during the operation phase, although the workforce would be 

12 smaller (40 workers), but similar volumes of truck traffic would occur as during operation, 

13 especially if the CPP is used for recovery of uranium-loaded ion-exchange (IX) resins from 

14 four potential satellite areas as well as for toll milling. 

15

16 Decommissioning: Impacts would be MODERATE, and with the continuing mitigation 

17 measures of the other lifecycle phases as well as the declining workforce, the impacts would 

18 be SMALL to MODERATE. The traffic volume during the decommissioning phase would be 

19 dominated by waste shipments for offsite disposal. Because of the reduced traffic volumes 

20 associated with this phase compared to the operations phase, there would be a reduced risk 

21 of transportation accidents. However, once the Ross Project has been fully 

22 decommissioned, all transportation impacts would be eliminated.

23

24 Geology and Soils 

25

26 Construction: Impacts to both geology and soils would be SMALL. Although the Ross 

27 Project’s design for its CPP would include a CBW, the impacts of the wall’s construction 

28 would be SMALL due to the relatively small and localized effects on the bedrock below it. 

29 The impacts on soils would occur largely during this phase of the proposed Ross Project, 

30 when most of the ground disturbance takes place. Potential soils impacts include soils loss 

31 (by wind and water erosion), soils compaction, increased salinity, soils-productivity loss, and 

32 soils contamination. Surface-disturbing activities would expose the soils and subsoils at the 

33 Ross Project area and would temporarily increase the potential for soil loss because of wind 

34 and water erosion. The Applicant, however, has proposed to remove vegetation only where 

35 necessary and would stockpile soils for reclamation during decommissioning. The Applicant

36 has proposed to mitigate erosion by minimizing the required land disturbances, ensuring 

37 timely re-vegetation and reclamation of affected soils, and installing drainage controls. 

38 Finally, the Applicant has proposed to mitigate wind erosion by limiting traffic speeds, 

39 spraying unpaved roads, and implementing timely disturbed-area reclamation. 

40

41 Operation: Impacts to local geology and soils would be SMALL. The removal of uranium 

42 from the target sandstone (aquifer) during ISR operation would change the mineralogical 

43 composition of uranium-bearing rock formations. However, no significant matrix compression 

44 or ground subsidence would be expected during in situ uranium recovery. Because the 

45 proposed operation would result in small changes in the reservoir pressure, the operation 

46 would be unlikely to activate any geologic faults. The potential for spills during transfer of 

47 uranium-bearing lixiviant to and from the CPP would be mitigated by implementing onsite 

48 best management practices (BMPs), standard operating procedures, and compliance with 

49 NRC license and WDEQ permit requirements. The potential impacts from soil loss would be 
DRAFT Executive Summary

xxvi

1 minimized by proper design and operation of surface-runoff features and implementation of 

2 BMPs.

3

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

5 ground-water sweep, ground-water transfer, ground-water treatment, and recirculation would 

6 not remove rock matrix or structure. The formation pressure would be managed during 

7 restoration to ensure that the direction of ground-water flow is into the wellfields to reduce the 

8 potential for lateral migration of constituents. The change in pressure would not be 

9 significant enough to result in matrix compression, ground subsidence, or to reactivate the 

10 fault. The spill response and leak detection activities would be the same as described during 

11 the operation phase. 

12

13 Decommissioning: Impacts would be SMALL. The potential impacts to the geology 

14 depend upon the density of plugged and abandoned drillholes and wells. At the end of 

15 decommissioning, the wellfields (whether recently operated or decommissioned some time 

16 ago) would contain approximately 3,000 drillholes and wells; these would include those 

17 drillholes from Strata’s ore-zone delineation efforts and geotechnical investigations, ground18 water monitoring wells used for site characterization, the injection and recovery wells from 

19 uranium-recovery activities, and Nubeth Joint Venture (Nubeth) drillholes and wells. This 

20 would represent an average density of approximately 4.3 wells/ha [1.7 wells/ac], which would 

21 be a low density with little geological impact. All areas of the Ross Project would be 

22 reclaimed and restored, so that the Project’s impacts on the soils would be small as well.

23

24 Water Resources (Surface Water and Wetlands) 

25

26 Construction: Impacts would be SMALL to both surface water quantity and quality as well 

27 as to wetlands. The Applicant intends to use surface water from either the Oshoto Reservoir 

28 or the Little Missouri River for dust control and construction. This equates to an annual use 

29 that is significantly less than the currently permitted annual appropriation for Oshoto 

30 Reservoir. Thus, the potential impacts of the Proposed Action’s construction to surface-water 

31 quantity would be SMALL. Suspended-sediment concentrations in storm water at the Ross 

32 Project area could be increased due to vegetation removal and soil disturbance during 

33 construction of the Proposed Action. However, given the site-specific mitigation measures to 

34 be implemented by the Applicant, the potential impacts of the Ross Project’s construction to 

35 surface-water quality would be SMALL. The potential impacts of the proposed Ross Project’s 

36 construction to wetlands would also be SMALL.

37

38 Operation: Impacts would be SMALL. Release of process solutions from uranium-recovery 

39 wellheads, pipelines, module buildings, or process vessels; accidental discharge from 

40 surface impoundments; or release of yellowcake or IX resin during a transportation accident 

41 could result in surface-water contamination if the release(s) reached a surface-water body. 

42 Given mitigation measures that the Applicant would employ, however, the potential impacts 

43 to surface-water quality during the operation of the Ross Project would be SMALL. Surface44 water monitoring and spill response would limit the impacts of potential surface spills to 

45 SMALL; however, impacts of spills to surface waters that are connected to shallow aquifers 

46 would be SMALL to MODERATE, depending upon the specifics of an incident. The 

47 Applicant’s compliance with its permit conditions, use of BMPs, and implementation of other 

48 required mitigation measures, however, would reduce the impacts of the Ross Project’s 

49 operation from MODERATE to SMALL, depending upon local conditions. 
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xxvii

1 Aquifer Restoration: Impacts would be SMALL. Potential risk of surface-water 

2 contamination associated with releases of process solutions and/or waste liquids as well as 

3 spills of other materials during aquifer restoration would be comparable to the operation 

4 phase of the Ross Project, but the uranium concentrations in such solutions would decline. 

5 Thus, the potential impacts of aquifer restoration to surface-water quantity and quality would 

6 be SMALL. The potential impacts during aquifer restoration to the wetlands on the Ross 

7 Project area would be the same as discussed under the Ross Project’s construction and they 

8 would be SMALL.

9

10 Decommissioning: Impacts would be SMALL. For the decommissioning of the Ross 

11 Project, the Applicant would use surface water from either the Oshoto Reservoir or the Little 

12 Missouri River for dust control during demolition activities. Potential surface-water 

13 contamination could occur from spilled or leaked fuel or lubricants from construction 

14 equipment and passenger vehicles that would be operated during decommissioning 

15 activities, although the equipment would generally be located away from surface-water 

16 bodies. The potential impacts from the Ross Project’s decommissioning to surface-water 

17 quantity and quality would be SMALL. As during all of the earlier phases, the potential 

18 impacts to wetlands from the Ross Project’s decommissioning would be SMALL.

19

20 Water Resources (Ground Water) 

21

22 Construction: Impacts would be SMALL. Potential impacts to the quantity of water in the 

23 shallow aquifers during construction of the Ross Project would be related to the quantity 

24 taken from the Oshoto Reservoir and the quantity involved in the installation of the CBW 

25 surrounding the facility. Any changes in ground-water levels due to water usage from Oshoto 

26 Reservoir would be small and restricted to the area around the Reservoir. Thus, the potential 

27 impacts during construction of the Ross Project to ground-water quantity in the shallow 

28 aquifers would be SMALL. Also, the potential impacts of the Proposed Action’s construction 

29 to ground-water quality in the shallow aquifers would be SMALL. Based upon yields from 

30 regional baseline wells and other wells, ground-water modeling indicates that the ore-zone 

31 aquifer could support this level of withdrawal with little drawdown. Thus, the potential 

32 construction impacts on the ground-water quantity available from the confined aquifers (ore33 zone, overlaying, and underlying aquifers) would be SMALL. Wells installed for further 

34 hydrologic studies, pre-licensing baseline site characterization (see SEIS Section 2.1.1.1), 

35 and production infrastructure would pass mechanical integrity testing (MIT) prior to use. 

36 Consequently, the potential impacts during construction on the ground-water quality in the 

37 confined aquifers would be SMALL. The potential impacts of construction on both the 

38 quantity and quality of ground water available from the deep aquifers would be SMALL.

39

40 Operation: The impact would range from SMALL to MODERATE (depending upon whether 

41 excursions occur). Potential impacts from operation to ground-water quantity in the shallow 

42 aquifers would be similar to those as during the construction phase and would be SMALL. 

43 The Applicant would implement spill control, containment, and cleanup measures in the CPP 

44 and surface-impoundment areas (i.e., the facility). These measures would include secondary 

45 containment for process-solution vessels and chemical storage tanks, a geosynthetic liner 

46 beneath the CPP’s foundation, dual liners with a leak-detection system for the surface 

47 impoundments, and a sediment impoundment to capture storm-water runoff. To reduce the 

48 risk of pipeline failure, the Applicant would hydrostatically test all pipelines prior to use and 

49 install leak-detection devices in manholes along the pipelines. The Applicant’s 
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xxviii

1 implementation of BMPs during Ross Project operation would reduce the likelihood and 

2 magnitude of spills or leaks and facilitate expeditious cleanup. The potential impacts from 

3 the Ross Project’s operation to ground-water quantity in the confined aquifers would be 

4 SMALL.

5

6 The potential impacts of ISR operation to ground-water quality in the confined aquifers above 

7 and below the ore zone would be SMALL. However, the short-term potential impacts of 

8 lixiviant excursions from uranium-recovery operation to the ore-zone aquifer outside the 

9 active ISR area would be SMALL to MODERATE. With respect to the deep aquifers where 

10 injection of liquid byproduct wastes would occur, regular monitoring of the water quality of the 

11 injected brine is required by the permit; thus, the potential impacts of the Ross Project’s 

12 operation to ground-water quantity and quality in the deep aquifers would be SMALL.

13

14 Aquifer Restoration: Impacts would be SMALL to MODERATE (due to potential significant 

15 drawdown in the ore-zone and confined aquifers, reducing ground-water quantity). The 

16 potential impacts to water quality would be reduced when compared to the Ross Project’s 

17 operation because no lixiviant would be used in the injection stream and the concentration of 

18 chemicals in the recovered ground water would be significantly less than during ISR 

19 operations. The Applicant’s implementation of BMPs during aquifer restoration would 

20 continue, and the other ground-water mitigation measures would be the same as those 

21 described for the operation of the Ross Project. Thus, the potential impacts of aquifer 

22 restoration to ground-water quantity and quality of the shallow aquifers would be SMALL. A 

23 conservative regional ground-water modeling analysis predicts a reduction in the available 

24 head in wells used for stock, domestic, and industrial use. These effects would be localized 

25 and short-lived. Consequently, the potential impacts of the Proposed Action’s aquifer26 restoration phase to ground-water quantity of the confined aquifers would be SMALL to 

27 MODERATE. In the deep aquifers, the volume of waste injected would be greater during the 

28 aquifer-restoration phase than during the Ross Project’s operation phase, but the potential 

29 impacts would be similar. The impacts from aquifer restoration to ground-water quantity and 

30 quality of the deep aquifers would, therefore, be SMALL.

31

32 Decommissioning: Impacts would be SMALL. After uranium-recovery operation is 

33 complete, unidentified, improperly abandoned wells (i.e., from previous subsurface 

34 explorations not associated with the Applicant or its activities could continue to impact 

35 aquifers above the ore-zone and adjacent aquifers by providing hydrologic connections 

36 between aquifers. Thus, the impacts to shallow aquifers during the Proposed Action’s 

37 decommissioning would be SMALL. As decommissioning proceeds at the Ross Project area, 

38 and the concomitant land reclamation and restoration activities proceed, all monitoring, 

39 injection, and production wells would be plugged and abandoned as noted above. The wells 

40 would be filled with cement and/or bentonite and then cut off below plow depth to ensure 

41 ground water does not flow through the abandoned wells. Proper implementation of these 

42 procedures would isolate the wells from ground-water flow. Thus, the impacts to the ore43 zone and adjacent confined aquifers would be SMALL. The Applicant estimates that very 

44 little brine and other liquid byproduct wastes would be disposed in the injection wells during 

45 the decommissioning (i.e., most wastes that would be generated during this phase would be 

46 solid). This small quantity would minimize potential impacts to ground-water quantity and 

47 quality during Ross Project’s decommissioning and they would be SMALL to the deep 

48 aquifers. 
DRAFT Executive Summary

xxix

1 Ecology

2

3 Construction: Impacts would be SMALL. Potential environmental impacts to ecology of the 

4 Ross Project area, including both flora and fauna, could include removal of vegetation from 

5 the Ross Project area; reduction in wildlife habitat and forage productivity, and an increased 

6 risk of soil erosion and weed invasion; the modification of existing vegetative communities as 

7 a result of uranium-recovery activities; the loss of sensitive plants and habitats; and the 

8 potential spread of invasive species and noxious weed populations. Impacts to wildlife could 

9 include loss, alteration, or incremental fragmentation of habitat; displacement of and stresses 

10 on wildlife; and direct and/or indirect mortalities. Aquatic species could be affected by 

11 disturbance of stream channels, increases in suspended sediments, pollution from fuel spills, 

12 and habitat reduction. However, construction of the Ross Project would be phased over time, 

13 reducing the amount of surface area disturbed at any one time. Thus, the impacts to 

14 terrestrial vegetation and terrestrial wildlife would be SMALL. Because aquatic habitats 

15 would be avoided if at all possible during construction, impacts to reptiles, amphibians, and 

16 fish during the Ross Project’s construction would also be SMALL.

17

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

19 experienced during the construction phase because fewer earth-moving activities would 

20 occur and traffic would be less. Due to the Applicant’s implementation of mitigation 

21 measures, such as wellfield perimeter and surface-impoundment fencing, leak-detection 

22 protocols, and wildlife protection and monitoring plans, the operation of the Ross Project 

23 would cause SMALL impacts to terrestrial vegetation and wildlife, including protected 

24 species, and to aquatic wildlife. 

25

26 Aquifer Restoration: Impacts would be SMALL. The potential impacts to ecological 

27 resources from aquifer-restoration activities would be similar to those experienced during the 

28 Ross Project’s operation phase; therefore, the potential impact to vegetation and wildlife 

29 would be SMALL. 

30

31 Decommissioning: No loss of vegetative communities beyond that disturbed during the 

32 construction phase would occur. Pipeline removal would impact vegetation that could have 

33 re-established itself, although this, too, would be temporary as the disturbed areas are 

34 reseeded. Thus, the impacts of the Ross Project’s decommissioning would not be expected 

35 to be greater than those experienced during its construction and would consequently be 

36 SMALL. 

37

38 Air Quality 

39

40 Construction: Impacts would be SMALL. Combustion-engine emissions from diesel- and 

41 gas-powered equipment operation would occur during all phases of the Ross Project. The 

42 heaviest use of such equipment, however, would be the construction and decommissioning 

43 phases of the Ross Project. Fugitive dusts would also be generated by both construction, 

44 land-clearing activities as well as by commuters and delivery trucks. The largest workforce of 

45 the Ross Project’s lifecycle would be employed on the Project’s construction, and their 

46 respective commutes increase local traffic quite significantly. Combustion-engine emissions 

47 and fugitive dust would be generated by all of this traffic. However, the predominant winds 

48 (in terms of both speed and direction) in the region, the remote location of the Ross Project 

49 area, and the air-quality control systems and the BMPs that would be implemented by the 

50 Applicant would all minimize the air-quality impacts of the Ross Project’s construction. In 
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1 addition, the requirements of the Applicant’s Air Quality Permit would require the Applicant to 

2 implement other specified mitigation measures as well, moderating the air emissions of the 

3 Ross Project. All anticipated gaseous-emission and fugitive-dust impacts would be limited in 

4 duration during the construction phase. Thus, the impacts of the Ross Project on air quality 

5 during construction would be SMALL and short-term.

6

7 Operation: Impacts would be SMALL. Air-quality impacts during the Ross Project’s 

8 operation phase would potentially include the same as those identified earlier for its 

9 construction phase (i.e., combustion-engine and fugitive-dust emissions). However, the 

10 quantity of the released air emissions would be reduced due to the reduced number of 

11 workers during ISR operation. Also, construction-equipment operation would decrease 

12 because most of the Ross Project area would have been cleared and graded during 

13 construction, so little earth movement would occur during operation; only the installation of 

14 wellfields would continue to generate fugitive dust. During uranium-recovery operation, 

15 several point sources of non-radioactive gaseous emissions would be located at the CPP. 

16 These would include process-pipelines, process-vessel, and storage-tank vents; emergency 

17 generators and space heaters; and other sources such as storage vessels and tanks 

18 containing acids and bases. However, these would all be very small point sources. 

19

20 Aquifer Restoration: Impacts would be SMALL. The emissions associated with the use of 

21 combustion-engine equipment would be limited in duration and result in small, short-term 

22 effects during the aquifer-restoration phase of the Ross Project. Vehicular traffic would be 

23 limited to delivery of supplies and commuting personnel; however, the workforce at the Ross 

24 Project would decrease to only 20 workers during aquifer restoration and, thus, the vehicular 

25 emissions of commuting traffic would substantially decrease. A significant decrease in the 

26 frequency of offsite yellowcake shipments would also occur as aquifer restoration proceeds. 

27

28 Decommissioning: Impacts would be SMALL. In the short term, emissions could increase 

29 somewhat, especially particulates because of decommissioning activities would generate 

30 particulate emissions such as fugitive dust. For example, the Applicant’s dismantling and 

31 demolition of buildings, structures, surface impoundments, and process equipment; removing 

32 contaminated soils; moving construction equipment to the different areas where 

33 decommissioning activities would take place; and the grading and re-contouring during site 

34 reclamation and restoration could all generate air emissions, particularly fugitive dust. 

35 Combustion-engine emissions would also be produced by heavy equipment as well as 

36 vehicles transporting workers to and from the Ross Project, where the workforce would 

37 increase at the initiation of the decommissioning phase. 

38

39 Noise 

40

41 Construction: Impacts would be SMALL to MODERATE. The nearest residents to the Ross 

42 Project area are substantially closer than those anticipated in the GEIS. Noise would be 

43 generated during construction activities as well as by vehicle traffic. Approximately 85 

44 percent of the overall construction workforce (i.e., 200 workers) would commute to the Ross 

45 Project area. Heavy-equipment operation within the Ross Project area would peak during the 

46 Applicant’s construction of the CPP, surface impoundments, wellfields, and associated 

47 infrastructure. In addition, the relocation of construction equipment to and from the Ross 

48 Project area and to and from different locations at the Ross Project area would generate 

49 noise. Impulse or impact noises from certain equipment, such as impact wrenches and 

50 pneumatic attachments on rock breakers, could be particularly loud as well. All of this noise 
DRAFT Executive Summary

xxxi

1 could occasionally be annoying to the closest nearby residents. The overall noise impacts 

2 during the Proposed Action’s construction would be SMALL to the general population, but the 

3 four closest residences to the Ross Project would experience MODERATE, but short-term, 

4 exposures to noise.

5

6 Operation: Impacts would be SMALL to MODERATE, with noise generated by construction 

7 activities greatly diminishing. The truck traffic associated with yellowcake, vanadium, and 

8 waste shipments would begin during the operation phase of the Ross Project; however, 

9 commuter-traffic noise would decrease due to the smaller workforce required during ISR 

10 operations (200 vs. 60 workers). However, because the county roads to and from the Ross 

11 Project area currently have very low average daily and annual traffic counts, there would be a 

12 continuing high relative increase in vehicular traffic and, thus, noise impacts to nearby 

13 residents would be MODERATE; the more distant local communities would experience only 

14 small, temporary impacts. The Applicant’s compliance with the Occupational Safety and 

15 Health Administration’s (OSHA’s) noise regulations would minimize impacts to workers. 

16

17 Aquifer Restoration: Impacts would be SMALL. During the Ross Project’s aquifer18 restoration phase, potential noise impacts would diminish to SMALL and would be only 

19 temporary for nearby residences. The workforce employed during aquifer restoration would 

20 be smaller (i.e., 20 worker) than during construction and operation phases of the Ross 

21 Project and, thus, there would be fewer workers, less traffic, and fewer noise-producing 

22 activities. The Applicant’s continued compliance with OSHA’s noise regulations would 

23 minimize impacts to workers. 

24

25 Decommissioning: Impacts would be SMALL to MODERATE. Noise levels during the 

26 decommissioning phase of the Ross Project would be similar to those identified for the 

27 construction phase, for both onsite and offsite receptors. Most potential impacts to nearby 

28 residential receptors would occur as a result of the anticipated significantly increased 

29 commuter and truck traffic to and from the Ross Project area during decommissioning (i.e., 

30 90 workers and additional waste shipments). At the Ross Project, despite the temporary 

31 nature of the decommissioning activities onsite, the short distance to the closest residences 

32 would make the noise impacts MODERATE.

33

34 Historical and Cultural Resources 

35

36 Construction: Impacts would be SMALL to LARGE. Archaeological and historical sites may 

37 potentially be disturbed by construction. Within the area of potential effect at the proposed 

38 Ross Project, 25 sites are being treated as eligible for listing on the National Register of 

39 Historic Places (NRHP) for the purposes of this NEPA analysis. Avoidance of sites that are 

40 not within the proposed disturbance areas is recommended. For sites within the proposed 

41 disturbance areas, avoidance and mitigation, such as fencing and data recovery excavations 

42 are recommended.

43

44 Prior to an NRC license being granted, an agreement between the NRC, the Wyoming State 

45 Historic preservation Office (WY SHPO), BLM, interested Native American Tribes, the 

46 Applicant, and other interested parties will be established outlining the mitigation process for 

47 each affected resource. Additionally, prior to construction, the Applicant will develop an 

48 Unexpected Discovery Plan that will outline the steps required if unexpected historical and 

49 cultural resources are encountered.
DRAFT Executive Summary

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1 Consultation efforts to identify properties of religious and cultural significance to Tribes have 

2 not been completed. Thus, the NRC cannot determine effects to these properties at this 

3 time. Section 106 consultation between NRC, WY SHPO, BLM, Tribal representatives, and 

4 the Applicant regarding potential impacts to these sites is ongoing.

5

6 Operation: Impacts would be SMALL. Minimal impacts will result during the operation 

7 phase because impacts to cultural resources will be mitigated before facility construction. If 

8 historical or cultural resources are encountered during operations, the Unexpected Discovery 

9 Plan will be implemented. Work would stop in the immediate area, and appropriate agencies 

10 would be notified. 

11

12 Aquifer Restoration: Impacts would be SMALL. Impacts to historical and cultural 

13 resources during the aquifer restoration phase will be similar to operations. Minimal impacts 

14 will result because impacts to cultural resources will be mitigated before facility construction, 

15 and identified resources will be avoided. If historical or cultural resources are encountered 

16 during aquifer restoration, the Unexpected Discovery Plan will be implemented. Work would 

17 stop in the immediate area, and appropriate agencies would be notified. 

18

19 Decommissioning: Impacts would be SMALL. Minimal impacts will result during the 

20 decommissioning phase because impacts to cultural resources will be mitigated prior to 

21 facility construction. If historical or cultural resources are encountered during 

22 decommissioning, the Unexpected Discovery Plan will be implemented. Work would stop in 

23 the immediate area, and appropriate agencies would be notified. 

24

25 Visual and Scenic Resources 

26

27 Construction: Impacts would be SMALL to MODERATE. The largest visible surface 

28 features of the Ross Project that would emerge during the construction phase would include 

29 wellhead covers and header houses; electrical and other utility distribution lines, which are 

30 mounted on 6-m [20-ft] wooden poles; more roads; the CPP; and the surface impoundments. 

31 There are protected visual resources near the Ross Project; the nearest such area is the 

32 Devils Tower National Monument, which is approximately 16 km [10 mi] east of the Ross 

33 Project. Although the Project itself would not be visible at the lower park portion of the 

34 Tower, climbers ascending to the top of the Tower may be able to see some of the Project’s 

35 largest attributes as well as, in the night sky, the lights of the Project. These lights would also 

36 be visible at residences near the Ross Project. The short-term visual contrasts with the 

37 characteristic landscape of the Ross Project area would result from construction activities. 

38 However, the construction activities proposed for the Ross Project would be consistent with 

39 the U.S. Bureau of Land Management (BLM) visual classification of this area. The 

40 management objective of Visual Resource Management (VRM) Class III is to partially retain 

41 the existing character of the landscape so that the level of change to the characteristic 

42 landscape can be moderate. Also, prior to construction of the Ross Project, the Applicant 

43 would conduct baseline monitoring for potential light pollution and develop a light-pollution 

44 monitoring plan that would finalize the locations for both continuous and intermittent light 

45 sources. The short-term construction activities at the proposed Ross Project would result in 

46 SMALL to MODERATE visual impacts to the nearest four residences, each of which has a 

47 view of the Ross Project area. For the remaining 7 of the 11 nearby residences, the visual 

48 impacts would be SMALL.
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xxxiii

1 Operation: Impacts would be SMALL. The overall visual impacts of an operating wellfield 

2 and the ISR facility itself would be small. In addition, the Ross Project would be located in 

3 gently rolling topography, where the visibility of aboveground infrastructure would vary and 

4 would be relative, depending upon the location and elevation of an observer as well as on 

5 nearby topography, total distance, and lighting characteristics. Lighting from the Ross 

6 Project would be visible from five of the residences to the east and from various locations 

7 directly to the west, north, and southeast. Mitigation measures for local light-pollution 

8 impacts would be the same as those described above for the construction phase of the Ross 

9 Project.

10

11 Aquifer Restoration: Impacts would be SMALL. Aquifer restoration activities would take 

12 place sequentially in the wellfields and last approximately two years per wellfield. There 

13 would be no modifications to either scenery or topography during aquifer restoration. Much 

14 of the same equipment and infrastructure used during operation would be employed during 

15 aquifer restoration, so that impacts to the visual landscape would be expected to be similar to 

16 or less than the impacts during the Proposed Action’s operation phase. The mitigation 

17 measures presented above for both the Proposed Action’s construction and operation 

18 phases would continue to be implemented during the aquifer-restoration phase, and these 

19 would continue to limit potential visual impacts.

20

21 Decommissioning: Impacts would be SMALL. The Ross Project would not result in 

22 significant impacts to the landscape that would persist after facility decommissioning and site 

23 restoration are completed. Most visual impacts during decommissioning would be temporary 

24 and diminish as structures, equipment, and other facility components are removed; the 

25 disturbed land surface is reclaimed and restored; and the vegetation is re-established. 

26

27 Socioeconomics 

28

29 Construction: Impacts would be SMALL to MODERATE. The Ross Project would employ 

30 approximately 200 people during construction, and this influx of workers would be expected 

31 to result in socioeconomic impacts, the greatest for communities with small populations. 

32 However, due to the short duration of construction, these workers would have only a limited 

33 effect on public services and community infrastructure. The Applicant is also committed to 

34 hiring locally—90 percent of the construction workforce would be local hires—so the overall 

35 socioeconomic impacts during the construction phase of the Ross Project would be SMALL. 

36 However the tax revenues paid to Crook County would be significant and, thus, that benefit 

37 would be a MODERATE impact of the Ross Project.

38

39 Operation: Impacts would be SMALL to MODERATE. If the majority of the operation 

40 workforce is local, the potential impacts to population and public services would continue to 

41 be SMALL. Because the Applicant is committed to hiring locally—80 percent of the operation 

42 workforce is expected to be local hires—the overall socioeconomic impacts during the Ross 

43 Project’s operation phase would continue to be SMALL, with MODERATE impacts 

44 associated with the additional tax revenues that would accrue to Crook County.

45

46 Aquifer Restoration: Impacts would be SMALL. The Applicant indicates that there would 

47 be a smaller workforce of only approximately 20 workers during the aquifer-restoration 

48 phase, without concurrent operations. The need for regulatory, management, and health and 

49 safety personnel would continue throughout aquifer restoration, but this need would be met 
DRAFT Executive Summary

xxxiv

1 by personnel transitioning from operation-phase work to aquifer restoration and no new 

2 personnel would necessarily be required. Thus, the impacts of the Ross Project’s aquifer3 restoration phase would likely be at most the same, or, more likely, less than those noted 

4 above for the Ross Project’s operation phase.

5

6 Decommissioning: Impacts would be SMALL. Because the size of the workforce during 

7 the Ross Project’s decommissioning phase would be initially be higher, but would subside as 

8 the decommissioning proceeds, there would be no significant socioeconomic impacts. In 

9 addition, socioeconomic impacts would no longer include tax revenues to Crook County 

10 during the decommissioning phase of the Ross Project and, thus, the earlier phases’ 

11 moderate impacts would be eliminated.

12

13 Environmental Justice 

14

15 All Phases: No minority or low-income populations were identified in the vicinity of the 

16 proposed Ross Project. Therefore, there would be no disproportionately high and adverse 

17 impacts to minority and low-income populations from the construction, operation, aquifer

18 restoration, and decommissioning of the Ross Project. 

19

20 Public and Occupational Health and Safety 

21

22 Construction: Impacts would be SMALL. Construction activities, including the use of 

23 construction equipment and vehicles, would disturb the topsoil and create fugitive dust 

24 emissions. Fugitive dust generated from construction activities would be short term (1 to 2 

25 years), and the levels of radioactivity in soils at the proposed project site are low; therefore 

26 direct exposure, inhalation, and ingestion of fugitive dust would not result in a significant 

27 radiological dose to workers or the public. Construction equipment would be diesel powered 

28 and would exhaust particulate diesel emissions. The potential impacts and potential human 

29 exposures from these emissions would be SMALL because of the short duration of the 

30 release and because the emissions would be readily dispersed into the atmosphere.

31

32 Operation: The radiological impacts from normal operations would be SMALL. Public and 

33 occupational exposure rates at ISR facilities during normal operations have historically been 

34 well below regulatory limits. Dose assessments using the MILDOS computer code indicate 

35 that the 10 CFR Part 20 public dose limit of 1 mSv/yr [100 mrem/yr] would not be exceeded 

36 at any property boundary. The remote location of the proposed Ross Project site and the use 

37 of the proposed ISR technology coupled with the Applicant’s proposed procedures to 

38 minimize exposure would cause the potential impact on public and occupational health and 

39 safety from facility operation to be SMALL. The radiological impacts from accidents would be 

40 SMALL for workers (if the Applicant’s radiation safety and incident response procedures in an 

41 NRC-approved radiation protection plan are followed) and SMALL for the public because of 

42 the facility’s remote location. The nonradiological public and occupational health and safety 

43 impacts from normal operations and accidents, due primarily to risk of chemical exposure, 

44 would be SMALL if handling and storage procedures are followed.

45

46 Aquifer Restoration: Impacts would be SMALL. Impacts would be similar to, but less than, 

47 those during the operations phase. The reduction or elimination of some operational 

48 activities would further reduce the magnitude of potential worker and public health impacts 

49 and safety hazards.
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1 Decommissioning: Impacts would be SMALL. Impacts would be similar to those 

2 experienced during construction. Soil and facility structures would be decontaminated, and 

3 lands would be restored to preoperational conditions.

4 Waste Management 

5

6 Construction: Impacts would be SMALL. No significant liquid wastes would be generated 

7 during the construction of the Ross Project. Most of the solid wastes expected to be 

8 generated during the construction phase would be general construction debris including 

9 paper, wood, plastic, and scrap metal. These nonhazardous solid wastes would be disposed 

10 of at a permitted solid-waste facility. Hazardous wastes, such as organic solvents, paints, 

11 and paint thinners, would be disposed of in accordance with the requirements in the 

12 Resource Conservation and Recovery Act (RCRA). No radioactive (byproduct) wastes 

13 would be generated during this phase at the Ross Project, although technologically enhanced 

14 naturally occurring radioactive material (TENORM) wastes would be generated during well 

15 drilling and these wastes would be managed onsite.

16

17 Operation: Impacts would be SMALL. Wastes generated during the operation of the Ross 

18 Project would primarily be liquid waste streams consisting of process bleed, where, after 

19 reverse-osmosis treatment, some excess permeate early in the Project’s operation and brine 

20 would be disposed of onsite at the five already permitted underground deep-injection wells. 

21 In addition, other liquid byproduct effluents would be generated as spent eluate, process22 drains liquids, contaminated reagents, filter-backwash liquids, wash-down water, and 

23 decontamination shower water. State permitting actions, NRC license conditions, and NRC 

24 inspections would ensure that proper waste-management practices are implemented by the 

25 Applicant to comply with safety requirements to protect workers and the public. 

26 Nonhazardous solid waste such as facility trash, tires, piping, valves, and instrumentation, 

27 would be reused, recycled, or disposed of at a nearby landfill or other waste-disposal facility, 

28 each of which has available disposal capacity. Domestic wastes would be treated and 

29 disposed of in an onsite sewage-treatment system.

30

31 Aquifer Restoration: Impacts would be SMALL. Water from aquifer restoration would be 

32 treated through a combination of ion exchange and reverse osmosis (RO) and then would be 

33 re-injected into the ore-zone aquifer to limit the volume of water permanently withdrawn. 

34 Concentrated liquid effluents generated by these activities would be disposed of via deep 

35 well disposal. Ordinary trash would continue to be shipped offsite for disposal.

36

37 Decommissioning: Impacts would be SMALL. The goal of decommissioning is to reduce 

38 potential impacts by removing contaminants to allowable (regulatory) levels and restoring the 

39 land of the Ross Project area to pre-licensing baseline conditions. The Applicant proposes to 

40 decontaminate and recycle much of the process equipment or to reuse it at other uranium41 recovery facilities. The Applicant would remove sludge from the storage ponds and liners 

42 and dispose of this material at a properly licensed radioactive-waste facility. Pre-operational 

43 agreements with a licensed radioactive-waste disposal facility to accept byproduct material 

44 would ensure the availability of sufficient disposal capacity for decommissioning activities. If 

45 hazardous waste is generated by decommissioning activities, it would be handled in 

46 accordance with applicable requirements. 
DRAFT Executive Summary

xxxvi

1 SUMMARY OF THE CUMULATIVE IMPACTS 

2

3 The cumulative impacts on the environment that would result from the incremental impact of 

4 the proposed Ross Project, when added to other past, present, and reasonably foreseeable 

5 future actions, was also considered. The NRC staff determined that the SMALL to LARGE

6 incremental impacts of the Ross Project would not contribute perceptible increases to the 

7 SMALL to LARGE cumulative impacts, due primarily to the extensive exploration taking place 

8 in the area for uranium, oil, and gas, and from coal mining. 

9

10 SUMMARY OF THE COSTS AND BENEFITS OF THE PROPOSED ACTION 

11

12 The implementation of the Proposed Action would generate primarily regional and local costs 

13 and benefits. The regional benefits of building the proposed Ross Project would be 

14 increased employment, economic activity, and tax revenues to the region around the 

15 proposed Ross Project area (i.e., Crook County). Costs associated with the Ross Project 

16 are, for the most part, limited to the area immediately surrounding the Ross Project area and 

17 include small visual, air-quality, and noise impacts. The NRC staff determined that the 

18 benefit from constructing and operating the uranium-recovery facility would outweigh the 

19 environmental and social costs. 

20

21 COMPARISON OF THE ALTERNATIVES 

22

23 Under the No-Action Alternative, Alternative 2, the NRC would not approve the license 

24 application for the proposed Ross Project. The No-Action Alternative would result in the 

25 Applicant not constructing, operating, restoring the aquifer of, or decommissioning the 

26 proposed ISR project. However, even if the proposed Ross Project is not licensed, the 

27 Applicant has already accomplished certain preconstruction activities (those activities that do 

28 not require an NRC license) at the Ross Project area. These previously completed 

29 preconstruction activities are evaluated as part of Alternative 2: No Action.

30

31 Under Alternative 3, the NRC would issue the Applicant a license for the construction, 

32 operation, aquifer restoration, and decommissioning of the proposed ISR project at the Ross 

33 Project, except that the entire ISR facility, including all buildings, other auxiliary structures, 

34 and the surface impoundments would be located north of where it is to be situated for the

35 Proposed Action. This alternate location for the ISR facility, referred as the “north site” by the 

36 Applicant (and referred to herein as the “North Ross Project”), was considered, but 

37 eliminated, by the Applicant in its license application. The north site is about 900 m [3,000 ft] 

38 northwest of where the facility would be located in the Proposed Action (referred to by the 

39 Applicant as the “south site”). An unnamed surface water drainage feature generally divides 

40 the north site. To avoid the floodplain of the drainage the Applicant would likely place the 

41 CPP and other buildings on one side of the drainage and the surface impoundments on the 

42 other side.

43

44 PRELIMINARY RECOMMENDATION 

45

46 After weighing the impacts of the Proposed Action and comparing the Alternatives, the NRC 

47 staff, in accordance with 10 CFR Part 51.71(f), sets forth its preliminary NEPA

48 recommendation regarding the Proposed Action. Unless safety issues mandate otherwise,

49 the preliminary NRC staff recommendation to the Commission related to the environmental
DRAFT Executive Summary

xxxvii

1 aspects of the Proposed Action is that a source and byproduct materials license for the

2 Proposed Action be issued as requested. The NRC staff concludes that the applicable 

3 environmental monitoring program described in Chapter 6 and the proposed mitigation 

4 measures discussed in Chapter 4 will eliminate or substantially lessen the potential adverse 

5 environmental impacts associated with the Proposed Action. 

6

7 The NRC staff has concluded that the overall benefits of the proposed action outweigh the 

8 environmental disadvantages and costs based on consideration of the following:

9

10 • Potential adverse impacts to all environmental resource areas are expected to be 

11 SMALL, with the exception of

12

13 1. Transportation resources during all phases of the proposed action. Increases in 

14 traffic during construction and operation would have a MODERATE to LARGE impact. 

15 Impacts would be MODERATE with mitigation for construction, operation, aquifer 

16 restoration, and decommissioning (See SEIS Sections 4.3.1.1, 4.3.1.2, 4.3.1.3, and 

17 4.3.1.4). 

18

19 2. Groundwater resources during operation and aquifer restoration. During operations 

20 there would be a MODERATE impact to ore-zone aquifer water quality due to 

21 excursions; however with measures in place to detect and resolve the excursions, the 

22 impacts would be reduced. During aquifer restoration there would be a MODERATE 

23 impact to ore-zone aquifer water quantity due to short-term drawdown (See SEIS 

24 Sections 4.5.1.2 and 4.5.1.3). 

25

26 3. Noise resources during construction, operations, and decommissioning. During these 

27 phases of the Ross Project there would be MODERATE impacts due to increased 

28 noise levels, however they would be intermittent and short term (See SEIS Sections 

29 4.8.1.1, 4.8.1.2 and 4.8.1.4). 

30

31 4. Historical and cultural resources during construction. Section 106 consultation and 

32 efforts to identify and determine the eligibility of historical and cultural resources that 

33 could be adversely affected by the proposed Ross Project are currently ongoing. 

34 Therefore, to be conservative in this draft SEIS, the NRC staff considers that 

35 construction could have a MODERATE to LARGE impact on historic properties, sites 

36 currently listed or eligible for listing on the National Register of Historic Places 

37 (NRHP)—and other unevaluated historic, cultural, and religious properties in the 

38 project area (See SEIS Section 4.9.1.1). However, once identification efforts are 

39 complete, mitigation efforts, which could require an MOA, would be developed to 

40 reduce impacts. The final SEIS will include the outcome of Section 106 consultation 

41 and would discuss mitigation measures, including an MOA, if one is developed. 

42

43 5. Visual and scenic resources during construction. There would be MODERATE 

44 impacts to residents near the Ross Project for the first year, however over the long 

45 term, impacts would be reduced (See SEIS Section 4.10.1.1).

46

47 6. Socioeconomic resources during construction and operations. There would be 

48 MODERATE impacts to Crook County during these phases of the Ross Project 

49 because taxes from the Project will be paid to the county (See Sections 4.11.1.1 and 

50 4.11.1.2).
DRAFT Executive Summary

xxxviii

1 • Regarding groundwater, the portion of the aquifer(s) designated for uranium recovery 

2 must be exempted as underground sources of drinking water before ISR operations 

3 begin. Additionally, Strata would be required to monitor for excursions of lixiviant from 

4 the production zones and to take corrective actions in the event of an excursion. Prior to 

5 operations, the Applicant would be required to provide detailed hydrologic pumping test 

6 data packages and operational plans for each wellfield at the Ross Project. Strata would 

7 also be required to restore groundwater parameters affected by the ISR operations to 

8 levels that are protective of human health and safety. 

9

10 • The costs associated with the Ross Project are, for the most part, limited to the area 

11 surrounding the site. 

12

13 • The regional benefits of building the proposed Project would be: increased employment, 

14 economic activity, and tax revenues in the region around the proposed Project site.
xxxix

LIST OF ABBREVIATIONS/ACRONYMS

AASHTO American Association of State Highway and Transportation Officials

ACL Alternate Concentration Limit

ADAMS Agencywide Documents Access and Management System

AEA Atomic Energy Act

ALARA As Low As Reasonably Achievable

APE Area of Potential Effect

APLIC Avian Power Line Interaction Committee

AQD Air Quality Division (Wyoming Department of Environmental Quality)

ARPA Archaeological Resources Protection Act of 1979

ASTM ASTM International (formerly American Society for Testing and Materials)

BACT Best Available Control Technology

BGS Below Ground Surface

BIA Bureau of Indian Affairs

BLM U.S. Bureau of Land Management (U.S. Department of the Interior)

BLMSS BLM’s Sensitive Species 

BLS Bureau of Labor Statistics (U.S. Department of Labor)

BMP Best Management Practice

CAA Clean Air Act

CBM Coal-Bed Methane

CBW Containment Barrier Wall

CCS Center for Climate Strategies

CEQ Council on Environmental Quality

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CESQG Conditionally Exempt Small Quantity Generator

CFR Code of Federal Regulations

CO Carbon monoxide

CO2 Carbon dioxide 

CPP Central Processing Plant

CR County Road

CWA Clean Water Act

dBA A-Weighted Decibels

DM Deep-Monitoring Zone or Unit

DOC U.S. Department of Commerce

DOI U.S. Department of the interior

EC Electrical Conductivity

EIA Energy Information Administration (U.S. Department of Energy)

EIS Environmental Impact Statement

EMR Emergency Medical Responder

EMT Emergency Medical Technician

EO Executive Order

EOR Enhanced Oil Recovery

EPA U.S. Environmental Protection Agency

ER Environmental Report 
xl

LIST OF ABBREVIATIONS/ACRONYMS

(Continued)

ESA Endangered Species Act

FHWA Federal Highway Administration (U.S. Department of Transportation)

GCRP U.S. Global Change Research Program

GEIS Generic Environmental Impact Statement 

HASP Health and Safety Plan

HDPE High-Density Polyethylene

HEC Hydrologic Engineering Center

HMS Hydrologic Modeling System

ISL In situ Leach

ISR In situ Recovery

IX Ion Exchange

LOI Letter of Intent

LQD Land Quality Division (Wyoming Department of Environmental Quality)

LSA Low Specific Activity

MARSSIM Multi-Agency Radiation Survey & Site Investigation Manual

MCL Maximum Contaminant Level

MIT Mechanical Integrity Testing

MOA Memorandum of Agreement

MOU Memorandum of Understanding

MSDS Material Safety Data Sheet

NAAQS National Ambient Air Quality Standards

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NPS National Park Service

NRC U.S. Nuclear Regulatory Commission

NRCS Natural Resources Conservation Service (U.S. Department of Agriculture)

NRHP National Register of Historic Places

NSDWUMR Nebraska-South Dakota-Wyoming Uranium Milling Region

Nubeth Nubeth Joint Venture

NWI National Wetlands Inventory

NWP Nationwide Permit (U.S. Army Corps of Engineers)

NWS National Weather Service

OSHA Occupational Safety & Health Administration (U.S. Department of Labor)

OSLI (Wyoming) Office of State Lands and Investments

OZ Ore Zone (Monitoring Interval or Aquifer)

Pb Lead

PCB Polychlorinated Biphenyl

PFYC Potential Fossil Yield Classification System
xli

LIST OF ABBREVIATIONS/ACRONYMS

(Continued)

pH Hydrogen Ion Activity

PM10 Particulate Matter 10 Microns or Less

PM2.5 Particulate Matter 2.5 Microns or Less

PPE Personal Protective Equipment

PRB Powder River Basin

PSD Prevention of Significant Deterioration

PSHA Probabilistic Seismic Hazard Analysis

PVC Polyvinyl Chloride

R Range or Roentgens

RAI Request for Additional Information

RCRA Resource Conservation and Recovery Act 

rem Roentgen Equivalent Man

RFFA Reasonably Foreseeable Future Actions

RMP Resource Management Plan

RO Reverse Osmosis

RPP Radiation Protection Program or Plan

SA Surficial Aquifer

SAR Sodium Adsorption Ratio

SEIS Supplemental Environmental Impact Statement

SER Safety Evaluation Report

SHPO State Historic Preservation Office

SM Shallow-Monitoring Zone

SMC USFWS’s Migratory Bird Species of Management Concern in Wyoming

SOP Standard Operating Procedure

SOW Scope of Work

Strata Strata Energy, Inc.

SWPPP Storm Water Pollution Prevention Plan

TCP Traditional Cultural Property

TDS Total Dissolved Solids

TEDE Total Effective Dose Equivalent

TENORM Technologically Enhanced Naturally Occurring Radioactive Material

THPO Tribal Historic Preservation Office

TLD Thermo Luminescent Dosimeter

TR Technical Report 

TSCA Toxic Substances Control Act

UCL Upper Control Limit

UIC Underground Injection Control

USACE U.S. Army Corps of Engineers

USCB U.S. Census Bureau (U.S. Department of Commerce)

USDA U.S. Department of Agriculture

USDOT U.S. Department of Transportation

USDW Underground Source of Drinking Water
xlii

LIST OF ABBREVIATIONS/ACRONYMS

(Continued)

USFS U.S. Forest Service

USFWS U.S. Fish and Wildlife Service

USGS U.S. Geological Survey

UW University of Wyoming

VRI Visual Resource Inventory 

VRM Visual Resource Management

WAAQS Wyoming Ambient Air Quality Standards

WDAI Wyoming Department of Administration and Information 

WDEQ Wyoming Department of Environmental Quality

WEUMR Wyoming East Uranium Milling Region

WGFD Wyoming Game and Fish Department

WOGCC Wyoming Oil and Gas Conservation Commission

WQD Water Quality Division (Wyoming Department of Environmental Quality)

WSEO Wyoming State Engineer's Office

WSGS Wyoming State Geological Survey

WSOC Wyoming Species of Concern 

WWC WWC Engineering

WWDC Wyoming Water Development Commission

WYCRO Wyoming Cultural Records Office

WYDOT Wyoming Department of Transportation

WYNDD Wyoming Natural Diversity Database

WYPDES Wyoming Pollutant Discharge Elimination System
xliii

SI* (MODERN METRIC) CONVERSION FACTORS

Approximate Conversions From SI Units

Symbol When You Know Multiply By To Find Symbol

Length

cm centimeters 0.39 inches in

m meters 3.28 feet ft

m meters 1.09 yards yd

km kilometers 0.621 miles mi

Areas

mm2 square millimeters 0.0016 square inches in2

m2 square meters 10.764 square feet ft2

m2 square meters 1.195 square yards yd2

Ha hectares 2.47 acres ac

km2 square kilometers 0.386 square miles mi2

Volume

mL milliliters 0.034 fluid ounces fl oz

L liters 0.264 gallons gal

m3 cubic meters 35.314 cubic feet ft3

m3 cubic meters 1.307 cubic yards yd3

m3 cubic meters 0.0008107 acre-feet acre-feet

Mass

g grams 0.035 ounces oz

kg kilograms 2.202 pounds lb

Mg (or “t”) megagrams

(or “metric ton”) 1.103 short tons(2,000 lb) T

Temperature (Exact Degrees)

0 Celsius 1.8C + 35 Fahrenheit 0

*SI is the symbol for the International System of Units. Appropriate rounding should be performed to comply with Section 4 of ASTM 

International’s “Standard for Metric Practice Guide.” West Conshohocken, Pennsylvania: ASTM International. Revised 2003.

DRAFT Introduction

1-1

1 1 INTRODUCTION

2

3 1.1 Background 

4

5 The U.S. Nuclear Regulatory Commission (NRC) prepared this Supplemental Environmental 

6 Impact Statement (SEIS) in response to an application Strata Energy, Inc. (Strata) (referred to 

7 herein as the Applicant) submitted on January 4, 2011, to develop and operate the proposed 

8 Ross In Situ Uranium Recovery (ISR) Project (herein referred to as Ross Project), located in 

9 Crook County, Wyoming (Strata, 2011a; Strata, 2011b). The Applicant is a wholly owned 

10 subsidiary of Peninsula Minerals, Ltd. Figure 1.1 shows the geographic location of the 

11 proposed project. This site-specific SEIS supplements the Generic Environmental Impact 

12 Statement (GEIS) for In Situ Leach Uranium Milling Facilities (herein referred to as GEIS) and 

13 was prepared in accordance with the process described in GEIS Section 1.8 (NRC, 2009) and 

14 as detailed in Section 1.4.1 of this SEIS. The NRC’s Office of Federal and State Materials and 

15 Environmental Management Programs prepared this SEIS as required by Title 10, Energy, of 

16 the U.S. Code of Federal Regulations (10 CFR), Part 51. These regulations implement the 

17 requirements of the National Environmental Policy Act of 1969 (NEPA), as amended (Public 

18 Law 91-190), which requires the Federal government to assess the potential environmental 

19 impacts of major federal actions that may significantly affect the human environment. 

20

21 The GEIS uses the terms “in-situ leach (ISL) process” and “11e.(2) byproduct material” to 

22 describe this uranium milling technology and the waste stream generated by this process. For 

23 the purposes of this SEIS, ISR is synonymous with ISL. The SEIS also uses the term 

24 “byproduct material” instead of “11e.(2) byproduct material“ to describe the waste stream 

25 generated by this milling process to be consistent with the definition in 10 CFR Part 40.4. 

26

27 1.2 Proposed Action 

28

29 On January 4, 2011, Strata submitted an application for an NRC source and byproduct material 

30 license to construct and operate an ISR facility at the proposed Ross Project site and to conduct 

31 aquifer restoration, site decommissioning, and reclamation activities. Based on the application, 

32 the NRC’s federal action is the decision to either grant or deny the license. The Applicant’s 

33 proposal is described in detail in SEIS Section 2.1.1. 

34

35 1.3 Purpose and Need of the Proposed Action 

36

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

38 Licensing of Source Material. The Applicant is seeking an NRC source material license to 

39 authorize commercial-scale ISR at the proposed Ross Project site. The purpose and need for 

40 the proposed action is to provide an option that allows the Applicant to recover uranium and to 

41 produce yellowcake slurry at the Ross Project site. Yellowcake is the uranium oxide product of 

42 the ISR milling process that is used to produce various products, including fuel for commercially 

43 operated nuclear power reactors.

44

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

46 findings in the safety review required by the Atomic Energy Act of 1954 (AEA), as amended, or 

47 findings in the NEPA environmental analysis that would lead NRC to reject a license application, 

48 NRC has no role in a company’s business decision to submit a license application to operate an 

49 ISR facility at a particular location. 
DRAFT Introduction

1-2

1

 Source: Strata, 2011a.

Figure 1.1 Ross Project Location
DRAFT Introduction

1-3

1 1.3.1 BLM’s Purpose and Need

2

3 The BLM purpose and need for the proposed action is to provide for orderly, efficient, and 

4 environmentally responsible mining of the uranium resource. The uranium resource is needed 

5 to fulfill market demands for this product for power generation and other needs. The proposed 

6 Ross Project area contains BLM-administered public lands open to mineral entry, and the 

7 Applicant has filed mining claims on them. The BLM federal decision is either to approve the 

8 Applicant’s Plan of Operations subject to mitigation included in the license application and this 

9 draft SEIS, or deny approval of the Plan of Operations. BLM’s responsibility to respond to the 

10 Applicant’s Plan of Operations establishes the need for the action. The mining claimant (Strata)

11 has the right to mine and to develop the mining claims as long as it can be done without causing 

12 unnecessary or undue degradation and is in accordance with pertinent laws and regulations 

13 under 43 CFR Part 3800.

14

15 1.4 Scope of the SEIS

16

17 The NRC staff prepared this SEIS to analyze the potential environmental impacts (i.e., direct, 

18 indirect, and cumulative impacts) of the proposed action and of reasonable alternatives to the 

19 proposed action. The scope of this SEIS considers both radiological and nonradiological 

20 (including chemical) impacts associated with the proposed action and its alternatives. This 

21 SEIS also considers unavoidable adverse environmental impacts, the relationship between 

22 short-term uses of the environment and long-term productivity, and the irreversible and 

23 irretrievable commitments of resources.

24

25 1.4.1 Relationship to the GEIS 

26

27 As described in Section 1.1, this SEIS supplements the GEIS, which was published as a final 

28 report in May 2009 (NRC, 2009). The final GEIS assessed the potential environmental impacts 

29 associated with the construction, operation, aquifer restoration, and decommissioning of an ISR 

30 facility that could be located in four specific geographic regions of the western United States. 

31 The proposed Ross Project is located in the Nebraska/South Dakota/Wyoming Uranium Milling 

32 Region. Table 1.1 summarizes the expected environmental impacts by resource area in the 

33 Nebraska-South Dakota-Wyoming Uranium Milling Region based on the GEIS analyses. 

34

35 The NRC conducted scoping activities for the purposes of defining the scope of GEIS and any 

36 future supplements to the GEIS. NRC staff accepted public comments on the scope of the 

37 GEIS from July 24, 2007, to November 30, 2007, and held three public scoping meetings, one 

38 of which was in the State of Wyoming. Additionally, NRC held eight public meetings to receive 

39 comments on the draft GEIS, published in July 2008. Three of these meetings were held in the 

40 State of Wyoming and one in nearby (Spearfish) South Dakota. Comments on the draft GEIS 

41 were accepted between July 28, 2008, and November 8, 2008. Comments received during 

42 scoping and on the draft GEIS were made available on the NRC website 

43 (http://www.nrc.gov/reading-rm/adams.html). Transcripts of the scoping meeting and draft GEIS 

44 comment meetings in Wyoming are available at http://www.nrc.gov/materials/uranium45 recovery/geis/pub-involve-process.html. 
DRAFT Introduction

1-4

1 

2 A scoping summary report was provided as GEIS Appendix A and GEIS Appendix G and 

3 provides responses to public comments on the draft GEIS (NRC, 2009).

4

5 In addition to the scoping activities conducted by NRC during preparation of the GEIS, NRC 

6 published ads, soliciting scoping comments on the Ross Project SEIS, in four local newspapers 

7 (Moorcroft Leader, Casper Star Tribune, Gillette News Record, and Sundance Times). The 

8 newspaper ad ran on December 2, 2011 in the Casper Star Tribune and December 1, 2011 for 

9 the other three papers. Scoping comments were received until December 30, 2011. In total, 19 

10 scoping comment letters were received containing a total of 53 individual comments. 

11

12 This SEIS was prepared to fulfill the requirement at 10 CFR Part 51.20(b)(8) to prepare either 

13 an environmental impact statement (EIS) or supplement to an EIS (SEIS) for the issuance of a 

14 source material license for an ISR facility (NRC, 2009). The GEIS provides a starting point for 

15 the NRC’s NEPA analyses for site-specific license applications for new ISR facilities, as well as 

16 for applications to amend or renew existing ISR licenses. As described in the GEIS, the GEIS 

Table 1.1

ISL GEIS Range of Expected Impacts in the Nebraska-South Dakota-Wyoming Uranium Milling 

Region 

Resource Area Construction Operation Aquifer 

Restoration

Decommissioni

ng

Land Use S S S S to M 

Transportation S to M S to M S to M S 

Geology and Soils S S S S 

Surface Water S to M S to M S to M S to M 

Groundwater S S to L S to M S 

Terrestrial 

Ecology 

S to M S S S 

Aquatic Ecology S S S S 

Threatened and 

Endangered 

Species 

S to L S S S 

Air Quality S S S S 

Noise S to M S to M S to M S 

Historical and 

Cultural 

Resources 

S to L S S S 

Visual and Scenic 

Resources 

S S S S 

Socioeconomics S to M S to M S S to M 

Public and 

Occupational 

Health and Safety 

S S to M S S 

Waste 

Management 

S S S S 

S: SMALL impact 

M: MODERATE impact 

L: LARGE impact 

Source: NRC, 2009 
DRAFT Introduction

1-5

1 provides criteria for each environmental resource area to assess the significance level of 

2 impacts (i.e., SMALL, MODERATE, or LARGE). The NRC staff applied these criteria to the site3 specific conditions at the proposed Ross Project. This SEIS tiers from, and incorporates by 

4 reference, the GEIS relevant information, findings, and conclusions concerning environmental 

5 impacts. The extent to which NRC staff incorporates the GEIS impact conclusions depends on 

6 the consistency between: (i) the Applicant’s proposed facilities and activities, and conditions at 

7 the Ross Project site; and (ii) the reference facility description, and activities, and information in 

8 the GEIS. NRC staff determinations regarding potential environmental impacts and the extent 

9 to which GEIS impact conclusions were incorporated by reference are described in Section 4 of 

10 this SEIS. GEIS Section 1.8.3 describes the relationship between the GEIS and a site-specific 

11 SEIS (NRC, 2009). 

12

13 1.4.2 Public Participation Activities 

14

15 As part of the preparation of this SEIS, NRC staff met with Federal, State, and local agencies 

16 and authorities, as well as public interest groups during a visit to the proposed Ross Project site 

17 and surrounding region in August 2011 (NRC, 2011a). The purpose of the meetings was to 

18 gather additional site-specific information to assist the NRC’s environmental review. 

19

20 The NRC staff published a Notice of Opportunity for Hearing on the proposed Ross Project 

21 license application in the Federal Register (FR) on July 13, 2011 (76 FR 41308). A hearing 

22 request from Petitioners Natural Resources Defense Council and Powder River Basin Resource 

23 Council was received on October 27, 2011. The NRC staff published a Notice of Intent (NOI) to 

24 prepare this SEIS on November 16, 2011 (76 FR 71082). In addition to the opportunities 

25 provided through the NEPA process, the NRC provided multiple opportunities for public 

26 involvement during the NRC staff’s safety review. Specifically, the NRC staff held 10 public 

27 meetings or teleconferences with the Applicant from 2010 through 2012. 

28

29 1.4.3 Issues Studied in Detail 

30

31 To meet its NEPA obligations related to its review of the Ross Project license application, the 

32 NRC staff conducted an independent, detailed, comprehensive evaluation of the environmental 

33 impacts from construction, operation, aquifer restoration, and decommissioning of an ISR facility 

34 at the proposed Ross Project site and from reasonable alternatives. As described in GEIS 

35 Section 1.8.3, the GEIS: (i) evaluated the types of environmental impacts that may occur from 

36 ISR uranium milling facilities; (ii) identified and assessed generic impacts (i.e., the same or 

37 similar) at all ISR facilities (or those with specified facility or site characteristics); and (iii) 

38 determined the scope of environmental impacts that needed to be addressed in site-specific 

39 environmental reviews. Therefore, although all of the environmental resource areas identified in 

40 the GEIS would be addressed in site-specific reviews, certain resource areas would require a 

41 more detailed site-specific analysis, because the GEIS determined a range in the significance of 

42 impacts (e.g., SMALL to MODERATE, SMALL to LARGE) could result, depending upon site43 specific conditions (see Table 1.1). 

44

45 Based on the GEIS analyses, this SEIS provides a site-specific analysis of the following 

46 resource areas:

47

48 • Land Use 

49 • Transportation 

50 • Geology and Soils 
DRAFT Introduction

1-6

1 • Transportation 

2 • Surface Water 

3 • Groundwater 

4 • Ecology 

5 • Threatened and Endangered Species 

6 • Air Quality 

7 • Noise 

8 • Visual and Scenic Resources

9 • Historic and Cultural Resources 

10 • Socioeconomics 

11 • Environmental Justice

12 • Public Health and Safety 

13 • Waste Management 

14

15 Furthermore, certain site-specific analyses not conducted in the GEIS, such as assessment of 

16 cumulative impacts, were considered in this SEIS. Additionally, the NRC considers the potential 

17 effects from implementing the proposed action on global climate change by estimating the 

18 facility’s greenhouse gas emissions, and also describes the potential effects of global climate 

19 change on the proposed action. 

20

21 1.4.4 Issues Outside the Scope of the SEIS 

22

23 Some issues and concerns raised during the scoping process on the GEIS (NRC, 2009, 

24 Appendix A) were determined to be outside the scope of the GEIS. These issues and concerns 

25 (e.g., general support or opposition for uranium milling, impacts associated with conventional 

26 uranium milling, comments regarding the alternative sources of uranium feed material, 

27 comments regarding energy sources, requests for compensation for past mining impacts, and 

28 comments regarding the credibility of NRC) are also outside the scope of this SEIS. 

29

30 1.4.5 Related NEPA Reviews and Other Related Documents 

31

32 A number of NEPA documents (environmental assessments [EAs] and environmental impact 

33 statements [EISs]) and other documents were reviewed and used in the development of this 

34 SEIS. The related documents are described below: 

35

36 • NUREG–1910, Generic Environmental Impact Statement for In-Situ Leach Uranium 

37 Milling Facilities, Final Report (NRC, 2009). As described previously, this GEIS was 

38 prepared to assess the potential environmental impacts from the construction, operation, 

39 aquifer restoration, and decommissioning of an ISR facility located in one of four different 

40 geographic regions of the western U.S. including the Nebraska/South Dakota/Wyoming 

41 Uranium Milling Region, where the proposed Ross Project would be located. The 

42 environmental analysis in this SEIS both tiers from the GEIS and incorporates it by 

43 reference. 

44

45 • NUREG–0706, Final Generic Environmental Impact Statement on Uranium Milling 

46 (NRC, 1980). This Generic EIS provides a detailed evaluation of the impacts and effects of 

47 anticipated conventional uranium milling operations in the United States through the year 

48 2000, including an analysis of tailings disposal programs. NUREG–0706 concluded the 

49 environmental impacts from underground mining and conventional milling would be more 
DRAFT Introduction

1-7

1 severe than using ISR technology. As described in SEIS Section 2.2.1, conventional mining 

2 and milling were considered, but eliminated from detailed analysis. 

3

4 • NUREG–1508, Final Environmental Impact Statement To Construct and Operate the 

5 Crownpoint Uranium Solution Mining Project, Crownpoint, New Mexico (NRC, 1997). 

6 This EIS evaluates the use of ISR technology at the Church Rock and Crownpoint sites at 

7 Crownpoint, New Mexico. Alternative uranium mining methods were not evaluated because 

8 the uranium ore located at the proposed sites was too deep to be extracted economically 

9 and the Final EIS concluded underground mining would have more significant environmental 

10 impacts than ISR recovery. 

11

12 • NRC’s Safety Evaluation Report. The NRC is preparing a Safety Evaluation Report (SER) 

13 for the proposed Ross Project that evaluates the Applicant’s proposed facility design, 

14 operational procedures, and radiation protection programs and whether the Applicant’s 

15 proposed action can be accomplished in accordance with the applicable provisions in 10 

16 CFR Part 20, 10 CFR Part 40, and 10 CFR Part 40, Appendix A. The SER also provides the 

17 NRC staff analysis of the Applicant’s initial funding estimate to complete site 

18 decommissioning and reclamation. 

19

20 • Newcastle Resource Management Plan EIS (BLM, 2000). This management plan 

21 addresses the Comprehensive Analysis of Alternatives for the Planning and Management of 

22 Public Land and Resources Administered by the U.S. Bureau of Land Management (BLM), 

23 Crook, Weston and Niobrara Counties, Wyoming. This EIS identifies activities occurring in 

24 the region surrounding the Ross Project site that could either affect or be affected by the 

25 proposed Ross Project. 

26

27 1.5 Applicable Regulatory Requirements 

28

29 NEPA establishes national environmental policy and goals to protect, maintain, and enhance 

30 the environment and provide a process for implementing these specific goals for those Federal 

31 agencies responsible for an action. This SEIS was prepared in accordance with NRC NEPA32 implementing regulations in 10 CFR Part 51 and other applicable regulations that were in effect 

33 at the time of writing. GEIS Appendix B summarizes other Federal statutes, implementing 

34 regulations, and Executive Orders that are potentially applicable to environmental reviews for 

35 the construction, operation, aquifer restoration, and decommissioning of an ISR facility. GEIS 

36 Sections 1.6.3.1 and 1.7.5.1 summarize the State of Wyoming’s statutory authority pursuant to 

37 the ISR process, relevant state agencies that are involved in the permitting of an ISR facility, 

38 and the range of state permits that would be required (NRC, 2009). 

39

40 1.6 Licensing and Permitting 

41

42 NRC has statutory authority through the AEA and the Uranium Mill Tailings Radiation Control 

43 Act of 1978 to regulate uranium ISR facilities. In addition to obtaining an NRC license, uranium 

44 ISR facilities must obtain the necessary permits from the appropriate Federal, State, local and 

45 Tribal governmental agencies. The NRC licensing process for ISR facilities is described in 

46 GEIS Section 1.7.1. GEIS Sections 1.7.2 through 1.7.5 describe the role of the other Federal, 

47 Tribal, and State agencies in the ISR permitting process (NRC, 2009). This section of the SEIS 

48 describes the NRC license application review process and summarizes the status of the NRC 

49 licensing process at the proposed Ross Project and the status of the Applicant’s permitting with 

50 respect to other applicable Federal, Tribal, and State requirements. 
DRAFT Introduction

1-8

1 1.6.1 NRC Licensing Process for the Ross Project 

2

3 By letter dated January 4, 2011, the Applicant submitted a license application to NRC for the 

4 proposed Ross Project (Strata, 2011a; Strata, 2011b). As described in GEIS Section 1.7.1, 

5 NRC initially conducts an acceptance review of a license application to determine whether the 

6 application is complete enough to support a detailed technical review. The NRC staff accepted 

7 the Ross Project license application for detailed technical review by letter dated June 28, 2011 

8 (NRC, 2011b). 

9

10 The NRC’s detailed technical review of the license application is composed of both a safety 

11 review and an environmental review. These two reviews are conducted in parallel (see GEIS 

12 Figure 1.7-1). The focus of the safety review is to assess compliance with the applicable 

13 regulatory requirements in 10 CFR Part 20 and 10 CFR Part 40, Appendix A. The 

14 environmental review is conducted in accordance with the regulations in 10 CFR Part 51. A 

15 Notice of Intent to prepare this SEIS was published in the Federal Register on November 16, 

16 2011 (76 FR 71082). 

17

18 The NRC hearing process (10 CFR Part 2) applies to licensing actions and offers stakeholders 

19 a separate opportunity to raise concerns associated with the proposed licensing actions. NRC 

20 published a Notice of Opportunity for Hearing related to the Ross Project license application on 

21 July 13, 2011 (76 FR 41308). NRC received a combined request for hearing from the Natural 

22 Resources Defense Council (NRDC) and Powder River Basin Resource Council (PRBRC) 

23 (collectively referred to as “Petitioners”) on October 27, 2011 (NRDC and PRBRC, 2011). 

24

25 Regulations in 10 CFR Part 2 specify that a petition for review and request for hearing must 

26 include a showing that the petitioner has standing and that the Atomic Safety and Licensing 

27 Board (ASLB) would rule on a petitioner’s standing by considering (i) the nature of the 

28 petitioner’s right under the AEA or NEPA to be made a party to the proceeding, (ii) the nature 

29 and extent of the petitioner’s property, financial, or other interest in the proceeding, and (iii) the 

30 possible effect of any decision or order that may be issued in the proceeding on the petitioner’s 

31 interest. Petitioners based their claim of standing on the possibility that the Ross Project would

32 jeopardize the economic and environmental interests of at least one of their members (NRDC 

33 and PRBRC, 2011).

34

35 On February 10, 2012, the ASLB ruled that Natural Resources Defense Council (NRDC) and

36 the Powder River Basin Resource Council (PRBRC) demonstrated standing to be parties to the 

37 licensing proceeding. The ASLB granted the petitioners’ request for a hearing and admitted four

38 contentions (ASLB, 2012).

39

40 1.6.2 Status of Permitting With Other Federal, Tribal, and State Agencies 

41

42 In addition to obtaining a source material license from NRC prior to conducting ISR operations 

43 at the proposed Ross Project site, the Applicant is required to obtain necessary permits and 

44 approvals from other Federal and State agencies to address (i) the underground injection of 

45 solutions and liquid effluent from the ISR process, (ii) the exemption of all or a portion of the ore 

46 zone aquifer from regulation under the Safe Drinking Water Act, and (iii) the discharge of storm 

47 water during construction and operation of the ISR facility. Table 1.2 lists the status of the 

48 required permits and approvals. 
DRAFT Introduction

1-9

1 1.7 Consultations 

2

3 As a Federal agency, NRC is required to comply with consultation requirements in Section 7 of 

4 the Endangered Species Act of 1973 (ESA), as amended, and Section 106 of the National 

5 Historic Preservation Act of 1966 (NHPA), as amended. The GEIS took a programmatic look at 

6 the environmental impacts of ISR uranium milling within four distinct geographic regions and 

7 acknowledged that each site-specific review would include its own consultation process with 

8 relevant agencies. Section 7 (ESA) and Section 106 (NHPA) consultations conducted for the 

9 proposed Ross Project are summarized in Sections 1.7.1 and 1.7.2. A list of the consultation 

10 correspondence is provided in SEIS Appendix A. Section 1.7.3 describes NRC coordination 

11 with other Federal, Tribal, State, and local agencies conducted during the development of the 

12 SEIS. 

13

14 1.7.1 Endangered Species Act of 1973 Consultation 

15

16 The ESA was enacted to prevent the further decline of endangered and threatened species and 

17 to restore those species and their critical habitats. Section 7 of the ESA requires consultation 

18 with the U.S. Fish and Wildlife Service (USFWS) to ensure that actions it authorizes, permits, or 

19 otherwise carries out would not jeopardize the continued existence of any listed species or 

20 adversely modify designated critical habitats. 

21

22 By letter dated August 12, 2011, NRC staff initiated consultation with USFWS requesting 

23 information on endangered or threatened species and critical habitat in the proposed Ross 

24 Project area. NRC received a response dated September 13, 2011, from the USFWS

25 Ecological Services Cheyenne, Wyoming Field Office that: (i) listed the threatened and 

26 endangered species that may occur in the project area; (ii) provided recommendations for 

27 protective measures for threatened and endangered species; and (iii) provided 

28 recommendations concerning migratory birds (USFWS, 2011). 

29

30 NRC staff also met with the Wyoming Game and Fish Department (WGFD) Sheridan Office on 

31 August 23, 2011, to discuss site-specific issues (NRC, 2011a). The Sheridan Office staff 

32 expressed concern about the potential impacts to water fowl, migratory birds, big game and 

33 small mammals, as well as sage grouse, a USFWS wait-list species for consideration as either 

34 threatened or endangered. WGFD staff also expressed concern about invasive species and 

35 impacts to wildlife due to power lines, evaporation ponds, and increased traffic. Impact 

36 mitigation measures were discussed. By letter dated, September 22, 2011, WGFD provided 

37 NRC with comments regarding the above concerns as follow up to the site visit (WGFD, 2011). 

38

39 1.7.2 National Historic Preservation Act of 1966 Consultation 

40

41 Section 106 of the NHPA requires that Federal agencies take into account the effects of their 

42 undertakings on historic properties and afford the Advisory Council on Historic Preservation 

43 (ACHP) an opportunity to comment on such undertakings. The Section 106 process seeks the 

44 views of consulting parties including the Federal agency, the State Historic Preservation Officer 

45 (SHPO), Indian tribes and Native Hawaiian organizations, Tribal Historic Preservation Officers 

46 (THPO), local government leaders, the Applicant, cooperating agencies, and the public. 

47
DRAFT Introduction

1-10

1 Table 1.2 

2 Environmental Approvals for the Proposed Ross Project

3

Issuing Agency Description Status 

Wyoming 

Department of 

Environmental 

Quality

UIC Class III Permit 

(WDEQ, Title 35-11) 

Received approval as part of Permit #802 

Underground Injection 

Control Class I (Deep 

Disposal Wells) (WDEQ, 

Title 35-11) 

Application submitted June 2010 to UIC 

program in Cheyenne, Wyoming; TFN 

#WYS-011-00031, Approved April 2011, 

Permit #10-263

Permit to Construct 

Domestic Wastewater 

System

To be prepared by Strata

Storm Water Discharge 

Permit (industrial/mining) To be prepared by Strata

Storm Water Discharge 

Permit (construction)

Approved January 2013, Permit 

#WYR104738

Storm Water Discharge 

Permit (discharge during 

well testing)

Approved April 2012, Permit 

#WYG720229, renewed December 2012

Permit to Mine Application submitted January 2011 to 

WDEQ District 3, Sheridan, Wyoming, TFN 

#5 6/110, Approved November 2012, 

Permit #802

Mineral Exploration Permit 

(WDEQ, Title 35-11) Approved #384DN

Air Quality Permit Approved CT-12198; September 2011 

Wastewater Pond 

Construction Permit (lined 

retention ponds and 

sediment pond)

To be prepared by Strata

Public Water Supply 

System – Permit to 

construct 

To be prepared by Strata

U.S. Bureau of 

Land 

Management 

Plan of Operation 

Submitted to BLM by Strata, January 2011; 

accepted for review July 2011, case file 

WYW170151 

Right of Way (roads) To be prepared by Strata

Notice of Intent to Explore To be prepared by Strata

U.S. Nuclear 

Regulatory 

Commission 

Source and Byproduct 

Materials License (10 CFR 

Part 40) 

Application under review (submitted 

January 2011; accepted June 2011)
DRAFT Introduction

1-11

1 Table 1.2 

2 Environmental Approvals for the Proposed Ross Project (Continued)

3

Issuing Agency Description Status 

U.S. 

Environmental 

Protection 

Agency 

Aquifer Exemption Permit 

for Class I Injection Wells 

(40 CFR 144, 146) 

See WDEQ permits; Wyoming has primacy 

for the UIC program 

Aquifer Reclassification for 

Class III Injection Wells 

(WDEQ, Title 35-11) 

Permit application to 

construct holding (storage) 

ponds (40 CFR 61.07) 

Public Water Supply 

System

To be prepared by Strata 

U.S. Army Corps 

of Engineers

Verification of Preliminary 

wetlands 

Application submitted September 2010; 

Verification received December 2010

Nationwide Permit 

Coverage authorization

Pre-construction notification submitted 

January 2013

Wyoming State 

Land & Farm 

Loan Office

Uranium Minerals Mining 

Lease 

Approved #0-40979

Wyoming 

Department of 

Environmental 

Quality and State 

Engineer’s Office 

Permit to Appropriate 

Groundwater for ISR 

Wellfield 

Under review, submitted December 2012

Permit to Appropriate 

Groundwater for Mine 

Wells 

Approved Permit #’s 191679-191702; 

192703-192705 (regional baseline monitor 

wells) 

To be prepared for ISR monitor wells 

Permits to Appropriate 

Surface Water and/ or 

Lined Retention Ponds and 

Sediment Pond

To be prepared by Strata

Crook County County Development 

Permits (access road 

approach and emergency 

services agreement) 

Memorandum of Understand between 

Crook County and Strata executed April 

2011. 

Source: WWC Engineering, 2013

4
DRAFT Introduction

1-12

1 The goal of consultation is to identify historic properties potentially affected by the undertaking, 

2 assess the effects of the undertaking on these properties, and seek ways to avoid, minimize, or 

3 mitigate any adverse effects on historic properties. As detailed in 36 CFR Part 800.2(c)(1)(i), 

4 the role of the Wyoming SHPO in the Section 106 process is to advise and assist Federal 

5 agencies in carrying out their Section 106 responsibilities.

6

7 NRC initiated consultation with the Wyoming SHPO by letter dated August 19, 2011, requesting 

8 information from the SHPO to facilitate the identification of historic and cultural resources that 

9 could be affected by the proposed project (NRC, 2011c). The NRC staff continues to consult 

10 with the Wyoming SHPO to evaluate the effects of the proposed project on historic and cultural 

11 resources.

12

13 NRC is also consulting with potentially affected Native American Tribes as part of the Section 

14 106 consultation process per 36 CFR Part 800.2(c). These interactions are detailed in Section 

15 1.7.3.3 of the SEIS. 

16

17 1.7.3 Coordination with Other Federal, Tribal, State, and Local Agencies 

18

19 The NRC staff interacted with Federal, Tribal, State, and local agencies and/or entities during 

20 preparation of this SEIS to gather information on potential issues, concerns, and environmental 

21 impacts related to the proposed ISR facility at the Ross Project site. The consultation and 

22 coordination process included discussions with BLM, National Park Service (NPS), Tribal 

23 governments, the Wyoming Department of Environmental Quality (WDEQ), WGFD, the 

24 Wyoming State Engineer’s Office (SEO), and local organizations (PRBRC, City of Moorcroft 

25 First Responders, and Crook County). 

26

27 1.7.3.1 Coordination with the Bureau of Land Management 

28

29 In its letter dated January 27, 2011, U.S. Bureau of Land Management (BLM) indicated its intent 

30 to serve as a cooperating agency in the NEPA assessment and licensing process for the 

31 proposed Ross Project, with the NRC serving as the lead agency. The proposed Ross Project 

32 site contains approximately 16 ha [40 ac] of BLM-administered surface lands. Additionally, BLM 

33 has jurisdiction over locatable mineral rights within the proposed project area. As discussed in 

34 Section 1.3, BLM’s responsibility for the proposed action is to fulfill its statutory responsibilities 

35 to regulate mining on federal lands as described in 43 CFR Part 3809. A Memorandum of 

36 Understanding between NRC and BLM (75 FR 1088), signed by BLM on October 16, 2009 and 

37 by NRC on November 30, 2009, provides the framework for the cooperating agency 

38 relationship. 

39

40 BLM is responsible for administering the National System of Public Lands and the federal 

41 minerals underlying these lands. BLM is also responsible for managing split estate situations 

42 where federal minerals underlie a surface that is privately held or owned by state or local 

43 government. In these situations, operators on mining claims, including ISR facilities, must 

44 submit a Plan of Operations and obtain BLM approval before beginning operations beyond 

45 those for casual use {for surface disturbance of more than 2 ha [5 ac]}. 

46

47 The NRC has coordinated with BLM during preparation of this SEIS. Regular conference calls 

48 and meetings have been held. The NRC staff met with the staff of BLM Newcastle, Wyoming 

49 field office on August 24, 2011 to discuss the Applicant’s Plan of Operations for the proposed 

50 Ross Project. BLM familiarized the NRC staff with the Plan of Operations review process and 
DRAFT Introduction

1-13

1 shared some of the comments and the concerns BLM had received from individuals 

2 commenting on the Plan of Operations. 

3

4 1.7.3.2 Interactions with Tribal Governments 

5

6 Pursuant to Section 106 of the NHPA, the NRC staff initiated discussions with potentially 

7 affected Native American Tribes that possess heritage and cultural interest to the proposed 

8 Ross Project area. On November 19, 2010, NRC sent a letter to 14 Tribes, notifying them of 

9 Strata’s intent to submit an application for a license for the Ross Project and soliciting input from 

10 the Tribes (NRC, 2010). NRC sent letters, dated February 9, 2011, to the following 24 Tribes, 

11 inviting the Tribes to participate in formal consultations for the proposed Ross Project (NRC, 

12 2011d):

13

14 • Apache Tribe of Oklahoma

15 • Blackfeet

16 • Cheyenne and Arapaho Tribes of Oklahoma

17 • Cheyenne River Lakota 

18 • Crow

19 • Crow Creek Sioux

20 • Eastern Shoshone

21 • Flandreau Santee Lakota 

22 • Fort Belknap Community

23 • Fort Peck Assiniboine/Sioux 

24 • Kiowa Tribe of Oklahoma

25 • Lower Brule Lakota

26 • Northern Arapaho

27 • Northern Cheyenne

28 • Oglala Lakota (Sioux)

29 • Rosebud Sioux

30 • Salish, Pend d’Oreille and Kootenai Tribes

31 • Santee Sioux Nation

32 • Sisseton-Wahpeton Lakota

33 • Spirit Lake 

34 • Standing Rock Sioux

35 • Three Affiliated Tribes (Mandan, Hidatsa, and Arikara Nation)

36 • Turtle Mountain Band of Chippewa Indians

37 • Yankton Lakota

38

39 The NRC staff continued its efforts to engage in consultation with Tribes that might be affected 

40 by the proposed action with follow-up telephone calls and by sending emails.

41

42 On April 15, 2011, the Rosebud Sioux Tribe notified the NRC via email that it was interested in 

43 consultation and had concerns about the proposed project (Rosebud Sioux Tribe, 2011). On 

44 April 29, 2011, the Standing Rock Sioux Tribe notified NRC via email of its desire to consult 

45 (Standing Rock Sioux Tribe, 2011). On May 5, 2011 the Northern Cheyenne Tribe notified NRC 

46 via email of its interest to consult (Northern Cheyenne Tribe, 2011). On May 17, 2011, the 

47 Cheyenne River Sioux Tribe notified NRC via email of its interest to consult on the proposed 

48 project (Cheyenne River Sioux Tribe, 2011). 
DRAFT Introduction

1-14

1 By letter dated April 14, 2011 the Tribal Historic Preservation Officer (THPO) for the Turtle 

2 Mountain Band of Chippewa Indians, informed NRC that it does not likely have any traditional 

3 cultural properties that would be of National Register significance at the Ross Project site (Turtle 

4 Mountain Band of Chippewa Indians, 2011). NRC was notified by email on August 19, 2011 

5 that the Apache Tribe of Oklahoma, was not interested in consultation on the Ross Project

6 (Apache Tribe of Oklahoma, 2011). The Salish, Pend d’Oreille and Kootenai Tribes notified 

7 NRC by email on December 29, 2011 that it would defer to nearer Tribes for consultation on the 

8 Ross Project (Salish, Pend d’Oreille and Kootenai Tribes, 2011).

9

10 The NRC staff, along with BLM staff, and the Applicant, conducted a site visit with 

11 representatives from the Northern Arapaho, the Northern Cheyenne, and the Fort Peck 

12 Assiniboine Sioux Tribes on September 13, 2011. The NRC staff and the BLM staff participated 

13 in a consultation meeting with the Northern Arapaho and the Northern Cheyenne Arapaho 

14 Tribes on September 14, 2011. On November 2, 2011, the NRC staff along with BLM staff, 

15 NPS staff for Devils Tower National Monument, and the Applicant conducted a second site visit 

16 with representatives from the Chippewa Cree, Crow Creek Sioux, Santee Sioux Nation, and the 

17 Fort Peck Assiniboine Sioux Tribes. On November 3, 2011, the NRC staff, BLM staff, and NPS 

18 staff participated in a consultation meeting with representatives from the Crow Creek Sioux, 

19 Santee Sioux Nation, and the Fort Peck Assiniboine Sioux Tribes. The Chippewa Cree Tribe 

20 expressed interest in consulting during planning for the second consultation meeting. 

21

22 During the September 2011 and November 2011 consultation meetings, the Tribes requested 

23 that a survey for properties of religious and cultural significance [or a Traditional Cultural 

24 Property (TCP) survey] of the Ross Project area be conducted. During the November 2011 site 

25 visit, Strata indicated that it would be willing to support such a survey. On December 6, 2011, 

26 the NRC sent a letter to Strata requesting a written proposal to acquire TCP information. Strata 

27 responded with a letter, dated January 12, 2012, in which it stated that in lieu of submitting a 

28 proposal for a TCP assessment of the Ross Project area, Strata would like to issue a Request 

29 for Proposals from consultants to prepare the TCP assessment. During conversations with 

30 several THPOs, the NRC staff was informed that the Tribes did not want to work with a third31 party consultant hired by the Applicant. Therefore, the NRC staff enlisted support from its own 

32 third-party consultant to work with the Tribes to obtain information on TCPs. 

33

34 At this time, the NRC staff was also working with many of the same Tribes to obtain TCP 

35 information for other ISR projects under NRC review. The Tribes consulting on the Ross Project 

36 suggested using a Scope of Work (SOW) that was being prepared for one of the other ISR 

37 projects under NRC review and revising it to be applicable for the Ross Project. The Tribes 

38 requested background information on the Ross Project area to assist them in developing a draft 

39 SOW for the Ross Project. This information was provided to the Tribes via email on July 25, 

40 2012. In August 2012, the NRC’s third-party consultant began reaching out to Tribes via phone 

41 and email to invite them to meet in Bismarck, North Dakota in early September to discuss the 

42 SOW as many of the Tribes were planning to be Bismarck at that time for a meeting with 

43 another agency. Strata provided a draft SOW to the NRC to be shared with the Tribes during 

44 the meeting. Sixteen Tribal representatives indicated that they would attend the meeting.

45 On September 4, 2012, the NRC’s third-party consultant met with representatives from the 

46 Standing Rock Sioux Tribe and the Three Affiliated Tribes in Bismarck, North Dakota. The 

47 Standing Rock Sioux Tribe representative indicated during this meeting that the Tribes did not 

48 want to use the SOW developed by Strata and would develop a draft SOW for the Ross Project. 

49 The Tribal representatives also indicated that a separate cost proposal would need to be 

50 developed for the TCP survey. In October and November 2012, the NRC staff worked with the 

51 representative from the Standing Rock Sioux Tribe to revise the SOW provided to the NRC by 
DRAFT Introduction

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1 the Tribes for another ISR project under NRC review to be applicable for the Ross Project. 

2 Also, on October 23, 2012, Strata hosted three representatives from the Makoche Wowapi 

3 company at the Ross Project site to facilitate the company’s preparation of a cost proposal for 

4 the TCP survey. The Makoche Wowapi company had submitted a cost proposal for a TCP 

5 survey for another ISR project under NRC review and many of the THPOs were discussing 

6 naming the company as the preferred consultant to conduct the TCP survey at the Ross Project 

7 site.

8

9 On November 13, 2012 and November 14, 2012, the NRC staff provided the draft SOW for the 

10 TCP survey to the THPOs and Strata, respectively, via email for review and comment. The 

11 THPOs held a teleconference to discuss the draft SOW on November 14, 2012 and invited the 

12 NRC staff to participate to answer questions. During the November 14, 2012 teleconference 

13 several THPOs indicated that the draft Scope of Work was acceptable and recommended that

14 the Makoche Wowapi company was their preferred consultant to conduct the survey.

15

16 The NRC staff shared the final SOW with the consulting THPOs via email on November 30, 

17 2012. After no comments were received, the NRC staff also shared the final SOW with the 

18 Makoche Wowapi company on December 4, 2012. On December 12, 2012, the Makoche 

19 Wowapi company submitted a cost proposal for the survey to the NRC. Strata notified the NRC 

20 staff, by email dated February 15, 2013, that its negotiations with Makoche Wowapi had come 

21 to an end and an agreement had not been reached. The NRC staff iscurrently consulting with 

22 the Tribes and Strata on an alternative approach to conduct a TCP survey. The survey is 

23 expected to be conducted during spring 2013. 

24

25 The Section 106 consultation process is ongoing. Results of the consultation will be presented 

26 in the final SEIS.

27

28 1.7.3.3 Coordination with National Park Service

29

30 NRC staff met with NPS staff at Devils Tower on August 25, 2011 (NRC, 2011a). NPS staff 

31 discussed the use of the monument by Tribes for cultural activities and prayers. NPS staff 

32 shared concerns about the night-sky viewshed and noise as well as potential impacts to 

33 groundwater quality. NPS is a “commenting agency” for this SEIS.

34

35 1.7.3.4 Coordination with the Wyoming Department of Environmental Quality 

36

37 NRC staff met with WDEQ in Sheridan, Wyoming, on August 23, 2011, to discuss the WDEQ 

38 role in the NRC environmental review process for ISR facilities (NRC, 2011a). WDEQ staff 

39 participating in the meeting included representatives from the Land Quality Division (LQD), 

40 Water Quality Division (WQD), and the Air Quality Division (AQD). Topics discussed during the 

41 meeting included the WDEQ air quality review and permitting as well as other required permits. 

42 The WDEQ expressed concern regarding the proposed location of the Central Processing Plant 

43 (CPP) and the evaporation ponds along with fugitive dust and emissions. 

44

45 NRC staff also met with personnel from the WDEQ in Casper, Wyoming on August 24, 2011 

46 (NRC, 2011a). WDEQ staff participating in the meeting included representatives from the WQD 

47 as well as the Solid and Hazardous Waste Division. The WDEQ explained the permitting 

48 process for land application of waste water and discussed solid waste management. 
DRAFT Introduction

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1 1.7.3.5 Coordination with the Wyoming Game and Fish Department 

2

3 WGFD is responsible for controlling, propagating, managing, protecting, and regulating all game 

4 and nongame fish and wildlife in Wyoming under Wyoming Statute (W.S.) 23-1-301-303 and 23-

5 1-401. Regulatory authority given to WGFD allows for the establishment of hunting, fishing, and 

6 trapping seasons, as well as the enforcement of rules protecting nongame and state-listed 

7 species. 

8

9 NRC staff met with a representative of the Sheridan Regional WGFD office on August 23, 2011 

10 (NRC, 2011a). As discussed in Section 1.7.1, WGFD staff expressed concerns about big game 

11 animals, raptors, migratory birds, and small mammals that may be affected by the proposed 

12 Ross Project and suggested mitigation strategies to minimize or eliminate impacts. 

13

14 1.7.3.6 Coordination with the City of Moorcroft First Responders 

15

16 NRC staff met with the City of Moorcroft First Responders on August 25, 2011 (NRC, 2011a). 

17 The City of Moorcroft First Responders briefed the NRC on the availability of local emergency 

18 equipment, personnel, and medical facilities. The emergency personnel discussed their need 

19 for additional training. The availability of land use plans and socioeconomic data was also 

20 discussed.

21

22 1.7.3.7 Coordination with the Powder River Basin Resource Council 

23

24 NRC staff met with PRBRC on August 23, 2011 (NRC, 2011a). PRBRC shared several 

25 concerns regarding the proposed Ross Project including concerns about the Applicant’s 

26 experience, potential direct and cumulative impacts to water quality, air quality, and ecology 

27 from operations, the potential for accidents and long-term effects, and restoration and excursion 

28 monitoring. 

29

30 1.7.3.8 Coordination with Localities 

31

32 NRC staff met with Crook County officials and staff on August 25, 2011, including 

33 representatives from the Crook County Sheriff’s Office, Crook County Attorneys, Crook County 

34 Road & Bridge, Crook County Natural Resource District, Crook County Weed & Pest, Crook 

35 County Commissioner, Crook County Growth & Development, and Crook County Emergency 

36 Management (NRC, 2011a). The Crook County officials and staff shared several concerns and 

37 asked many questions about the proposed Ross Project. Topics discussed included the 

38 chemical and radiological hazards associated with the project, the management of boreholes 

39 and the potential for drinking water contamination, water use, financial assurance, solid waste 

40 management, invasive species, decommissioning, and cumulative impacts.

41

42 1.8 Structure of the SEIS 

43

44 As noted in Section 1.4.1 of this document, the GEIS (NRC, 2009) evaluated the broad impacts 

45 of ISR projects in a four-state region where such projects are anticipated, but did not reach site46 specific decisions for new ISR projects. The NRC staff evaluated the extent to which 

47 information and conclusions in the GEIS could be incorporated by reference into this SEIS. The 

48 NRC staff also determined whether any new and significant information existed that would 

49 change the expected environmental impact beyond what was evaluated in the GEIS. 
DRAFT Introduction

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1 SEIS Section 2 describes the proposed action and reasonable alternatives considered for the 

2 proposed Ross Project, Section 3 describes the affected environment, and Section 4 evaluates 

3 the environmental impacts from implementing the proposed action and alternatives. Cumulative 

4 impacts are discussed in Section 5, while Section 6 describes the environmental measurement 

5 and monitoring programs proposed for the Ross Project. A cost-benefit analysis is provided in 

6 Section 7, and the environmental consequences from the proposed action and alternatives are 

7 summarized in Section 8. 

8

9 1.9 References 

10

11 10 CFR Part 2. Code of Federal Regulations, Title 10, Energy, Part 2, “Rules of Practice for

12 Domestic Licensing Proceedings and Issuance of Orders.” Washington, DC: U.S. Government

13 Printing Office.

14

15 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for

16 Protection Against Radiation.” Washington, DC: U.S. Government Printing Office.

17

18 10 CFR Part 40. Code of Federal Regulations, Title 10, Energy, Part 40, Domestic Licensing of

19 Source Material, Washington, DC: U.S. Government Printing Office. 2010.

20

21 10 CFR Part 40. Appendix A. Code of Federal Regulations, Title 10, Energy, Part 40, Appendix

22 A, “Criteria Relating to the Operation of Uranium Mills and to the Disposition of Tailings or

23 Wastes Produced by the Extraction or Concentration of Source Material from Ores Processed

24 Primarily from their Source Material Content.” Washington, DC: U.S. Government Printing

25 Office.

26

27 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

28 Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

29 Washington, DC: U.S. Government Printing Office.

30

31 75 FR 1088. Federal Register, Vol. 75, No. 1497, p. 1088, “Notice of Availability of a 

32 Memorandum of Understanding between the Nuclear Regulatory Commission and the Bureau 

33 of Land Management.” January 8, 2010. 

34

35 76 FR 41308. Federal Register, Vol. 76, No. 134, p. 41308-41312. “Strata Energy, Inc. Ross In 

36 Situ Recovery Uranium Project, Crook County, WY; Notice of Materials License Application, 

37 Opportunity to Request a Hearing and To Petition for Leave To Intervene, and Commission 

38 Order Imposing Procedures for Document Access to Sensitive Unclassified Non-Safeguards 

39 Information for Contention Preparation.” July 13, 2011. Agencywide Documents Access and 

40 Management System (ADAMS) Accession No. ML111940012. 

41

42 76 FR 71082. Federal Register, Vol. 76, No. 221, p. 71082-71083. “Strata Energy, Inc., Ross 

43 Uranium Recovery Project; New Source Material License Application; Notice of Intent to 

44 Prepare a Supplemental Environmental Impact Statement.” November 16, 2011.

45

46 Apache Tribe of Oklahoma. “RE: Ross Consultation.” E-mail (August 19) from L. Guy to A. 

47 Bjornsen, Project Manager, Office of Federal and State Materials and Environmental 

48 Management Programs, U.S. Nuclear Regulatory Commission. Anadarko, OK: Apache Tribe 

49 of Oklahoma. 2011. Accession No. ML11336A224. 
DRAFT Introduction

1-18

1 ASLB (Atomic Safety and Licensing Board). “Memorandum and Order (Ruling on Standing and 

2 Contention Admissibility).” In the Matter of Strata Energy, Inc. (Ross In Situ Recovery Uranium 

3 Project). Docket No. 40-9091-MLA. ASLBP No. 12–915–01–MLA–BD01. February 10, 2012. 

4 Accession No. ML12041A295.

5

6 BLM (Bureau of Land Management). “Newcastle Resource Management Plan.” Newcastle, 

7 WY: BLM. 2000. ADAMS Accession No. ML12209A101. 

8

9 Cheyenne River Sioux Tribe. E-mail (May 17) from S. Vance to A. Bjornsen, Project Manager, 

10 Office of Federal and State Materials and Environmental Management Programs, U.S. Nuclear 

11 Regulatory Commission. Eagle Butte, SD: Cheyenne River Sioux Tribe. 2011. ADAMS 

12 Accession No. ML11336A442. 

13

14 (US)FWS (U.S. Fish and Wildlife Service). Cheyenne, Wyoming: USFWS. September 13, 

15 2011. ADAMS Accession No. ML112770035. 

16

17 Northern Cheyenne Tribe. “Re: Ross Letter Inviting Section 106 Consultation.” E-mail (May 5) 

18 from C. Fisher to A. Bjornsen, Project Manager, Office of Federal and State Materials and 

19 Environmental Management Programs, U.S. Nuclear Regulatory Commission. Lame Deer, MT: 

20 Northern Cheyenne Tribe. 2011. ADAMS Accession No. ML11337A064. 

21

22 (US)NRC (U.S. Nuclear Regulatory Commission). “Site Visit and Informal Information 

23 Gathering Meetings Summary Report for the Proposed Ross In Situ Recovery Project (Docket 

24 No. 040-09091).” Memorandum (November 28) to K. Hsueh, Branch Chief from A. Bjornsen, 

25 Project Manager, Office of Federal and State Materials and Environmental Management 

26 Programs. Washington, DC: NRC. 2011a. ADAMS Accession No. ML112980194. 

27

28 (US)NRC. “Acceptance for Review of Materials License Application, Strata Energy, Inc., Ross 

29 In Situ Recovery Uranium Project, Crook County, Wyoming (TAC J00640).” Washington, DC: 

30 NRC. 2011b. ADAMS Accession No. ML111721948. 

31

32 (US)NRC. “Initiation Of Section 106 Consultation For Strata Energy, Inc’s Proposed Ross 

33 Uranium Recovery Project – License Request (Docket 040-09091).” Washington, DC: NRC. 

34 2011c. ADAMS Accession No. ML112150393. 

35

36 (US)NRC. “Invitation For Formal Section 106 Consultation Pursuant To The National Historic 

37 Preservation Act Regarding the Strata Energy, Inc. License Application for the Proposed 

38 Uranium In-Situ Recovery Facility, in Oshoto, Crook County, Wyoming to Cheyenne River 

39 Lakota Tribe (ML110040131), Blackfeet Tribe (ML110040076), Yankton Lakota 

40 (ML110040312), Spirit Lake Tribe (ML110040484), Apache Tribe (ML110310152) Oglala Sioux 

41 Tribe (ML110400125),Three Affiliated Tribes (ML110400293), Fort Peck Assiniboine and Sioux 

42 Tribe (ML110400344), Standing Rock Sioux Tribe (ML110400258), Eastern Shoshone Tribe 

43 (ML110400199), Cheyenne and Arapaho of OK Tribe (ML110400090), Flandreau Santee 

44 Lakota Tribe (ML110400285), Crow Creek Sioux Tribe (ML110400225), Northern Cheyenne 

45 (ML110400529), Santee Sioux Nation (ML110400181), Fort Belknap Community Tribe 

46 (ML110400311), Sisseton-Wahpeton Oyate (ML110400222), Northern Arapaho Tribe 

47 (ML110400508), Rosebud Sioux Tribe (ML110400154), Confederated Salish and Kootenai 

48 Tribe (ML110400176), Turtle Mountain Band of Chippewa Tribe (ML110400279), Crow Tribe 

49 (ML110400256), Kiowa (ML110400461), and Lower Brule Tribe (ML110400489).” Washington, 

50 DC: NRC. 2011d.
DRAFT Introduction

1-19

1 (US)NRC. “Notification of Proposed Facility – Strata Energy, Inc., Ross Uranium In Situ 

2 Recovery Facility, Oshoto, Crook County, Wyoming.” Washington, DC: NRC. 2010. ADAMS 

3 Accession No. ML103160580. 

4

5 (US)NRC. NUREG–1910. “Generic Environmental Impact Statement for In Situ Leach Uranium 

6 Milling Facilities–-Final Report.” Washington, DC: NRC. May 2009. ADAMS Accession Nos. 

7 ML091480244 and ML091480188. 

8

9 (US)NRC. NUREG–1508. “Final Environmental Impact Statement to Construct and Operate the 

10 Crownpoint Uranium Solution Mine Project, Crownpoint, New Mexico.” Washington, DC: 

11 NRC. February 1997. ADAMS Accession No. ML082170248.

12

13 (US)NRC. NUREG–0706. “Final Generic Environmental Impact Statement on Uranium Milling 

14 Project M-25.” Washington, DC: NRC. September 1980. ADAMS Accession Nos. 

15 ML032751663, ML0732751667, and ML032751669. 

16

17 NRDC and PRBDC. “Petition to Intervene and Request for Hearing by the Natural Resource 

18 Defense Council and Powder River Basin Resource Defense Council.” Washington, DC: 

19 NRDC. 2011. ADAMS Accession No. ML11300A188.

20

21 Rosebud Sioux Tribe. “RE: Ross Uranium ISR Project.” E-mail (April 15) from R. Bordeaux to A.

22 Bjornsen, Project Manager, Office of Federal and State Materials and Environmental 

23 Management Programs, U.S. Nuclear Regulatory Commission. Rosebud Sioux Tribe. 2011.

24 ADAMS Accession No. ML111220299. 

25

26 Salish, Pend d’Oreille and Kootenai Tribes. “December 6th Letter.” E-mail (December 29) from 

27 F. Auld to A. Bjornsen, Project Manager, Office of Federal and State Materials and 

28 Environmental Management Programs, U.S. Nuclear Regulatory Commission. Salish, Pend 

29 d’Oreille and Kootenai Tribes. 2011. ADAMS Accession No. ML120050552. 

30

31 Standing Rock Sioux Tribe. E-mail (April 29) from W. Young to A. Bjornsen, Project Manager, 

32 Office of Federal and State Materials and Environmental Management Programs, U.S. Nuclear 

33 Regulatory Commission. Fort Yates, ND: Standing Rock Sioux Tribe. 2011. ADAMS 

34 Accession No. ML11337A071. 

35

36 Strata “Ross ISR Project USNRC License Application, Crook County, Wyoming, Environmental 

37 Report, Volumes 1, 2 and 3 with Appendices.” Docket No. 40-09091. Gillette, WY: Strata 

38 Energy, Inc. 2011a. ADAMS Accession Nos. ML110130342, ML110130344, and 

39 ML110130348.

40

41 Strata. “Ross ISR Project USNRC License Application, Crook County, Wyoming, Technical 

42 Report, Volumes 1 through 6 with Appendices.” Docket No. 40-09091. Gillette, WY: Strata. 

43 2011b. ADAMS Accession Nos. ML110130333, ML110130335, ML110130314, ML110130316, 

44 ML110130320, and ML110130327.

45

46 Turtle Mountain Band of Chippewa Indians. E-mail (April 14) from K. Ferris to A. Bjornsen,

47 Project Manager, Office of Federal and State Materials and Environmental Management 

48 Programs, U.S. Nuclear Regulatory Commission. Belcourt, ND: Turtle Mountain Band of 

49 Chippewa Indians. 2011. ADAMS Accession No. ML111080059. 
DRAFT Introduction

1-20

1 WWC Engineering. “Re: Request Update of ER Table 1.6-a.” E-mail (February 1) from B. 

2 Schiffer to J. Moore, Project Manager, Office of Federal and State Materials and Environmental 

3 Management Programs, U.S. Nuclear Regulatory Commission. Sheridan, Wyoming: WWC 

4 Engineering. 2013. ADAMS Accession No. ML13035A012. 

5

6 Wyoming Game and Fish Department (WGFD). Cheyenne, Wyoming: WGFD. 2011. ADAMS 

7 Accession No. ML112660130. 
DRAFT In Situ Uranium Recovery and Alternatives

2-1

1 2 IN SITU URANIUM RECOVERY AND ALTERNATIVES

2

3 This section describes the Proposed Action, which is 

4 to issue a U.S. Nuclear Regulatory Commission 

5 (NRC) source and byproduct material license to Strata 

6 for the proposed Ross Project in northeastern 

7 Wyoming. Strata would use its NRC license in 

8 connection with the construction, operation, aquifer 

9 restoration, and decommissioning of the proposed 

10 Ross Project. This section also discusses alternatives 

11 to the proposed action, including the No-Action 

12 alternative as required under the National 

13 Environmental Policy Act of 1969 (NEPA). 

14

15 Figure 2.1 indicates the proposed location of the 

16 Ross Project. Section 2.1 of this Supplemental 

17 Environmental Impact Statement (SEIS) describes the 

18 Alternatives that are included for detailed analysis, including the Proposed Action; Section 2.2 

19 describes those alternatives that were considered but eliminated from detailed analysis; Section 

20 2.3 summarizes the potential environmental impacts of the Proposed Action and the two 

21 Alternatives; and Section 2.4 discusses the NRC staff’s preliminary recommendation that the 

22 NRC issue a source and byproduct materials license for the Proposed Action unless safety 

23 issues mandate otherwise. 

24

25 2.1 Alternatives Considered for Detailed Analysis

26

27 In addition to the Proposed Action, two alternatives to the Ross Project are also considered in 

28 this SEIS. All alternatives are evaluated with regard to the four phases of an uranium-recovery 

29 operation: construction, operation, aquifer restoration, and decommissioning. The range of 

30 alternatives has been established based on the purpose and need statement as described in 

31 Section 1.3 of this SEIS. In addition, this SEIS adopts many of the conclusions reached in the 

32 GEIS that was prepared for in situ recovery (ISR) projects (NRC, 2009).

33

34 Alternatives examined in this SEIS are:

35

36 ■ Alternative 1 is the Proposed Action, as described in the Applicant’s license application. 

37 The Proposed Action is described in SEIS Section 2.1.1.

38 ■ Alternative 2 is the No-Action Alternative, as required by the National Environmental Policy 

39 Act (NEPA), where the Applicant would not construct, operate, restore the aquifer, or 

40 decommission the Ross Project. Alternative 2 is described in SEIS Section 2.1.2.

41 ■ Alternative 3 is the same as the Proposed Action, except that the Ross Project facility (i.e., 

42 the central processing plant [CPP], auxiliary and support buildings and structures, and the 

43 surface impoundments) would be situated at a different location to the north of the Proposed 

44 Action (i.e., at the “north site”). Alternative 3 is identified in this SEIS as the “North Ross 

45 Project” and is described in SEIS Section 2.1.3.

46

47 The sources of information used in the development of this SEIS include the following: the 

48 Applicant’s license application, including its Environmental Report (ER) (Strata, 2011a) and its 

49 Technical Report (TR) (Strata, 2011b) as well as its Responses to Requests for Additional 

50

What is source material?

“Source material” means either the 

element thorium or the element uranium, 

provided that the uranium has not been 

enriched with the radioisotope uranium235.

What is byproduct material?

 

 

 

 

 

What is source material?

“Source material” means either the 

element thorium or the element uranium, 

provided that the uranium has not been 

enriched with the radioisotope uranium235. 

What is byproduct material?

“Byproduct materials” are tailings or 

wastes generated by extraction or 

concentration of uranium or thorium 

processed ores, as defined under

Section 11e.(2) of the Atomic Energy Act 

(AEA).
DRAFT In Situ Uranium Recovery and Alternatives

2-2

1

2

Figure 2.1

Ross Project Within the Lance District

Source: Strata, 2012a.
DRAFT In Situ Uranium Recovery and Alternatives

2-3

1 Information (RAIs) (Strata, 2012a; Strata, 2012b); the information and scoping comments 

2 gathered during the NRC staff’s and NRC consultants’ site visit in August 2011 (NRC, 2011); 

3 information independently researched by the NRC staff from publicly available sources; 

4 multidisciplinary discussions held among NRC staff and various stakeholders; and the Generic 

5 Environmental Impact Statement (GEIS) itself (NRC, 2009).

6

7 2.1.1 Alternative 1: Proposed Action

8

9 Under the Proposed Action, the NRC would issue the applicant a source material license. The 

10 Applicant would use its NRC license in connection with the construction, operation, aquifer 

11 restoration, and decommissioning of the ISR facility at the Ross Project area as described in its 

12 license application (Strata, 2011a; Strata, 2011b). Also, under the proposed action, the U.S. 

13 Bureau of Land Management (BLM) would approve the Applicant’s Plan of Operations (POO). 

The Ross Project would occupy 697 ha [1,721 ac] in the north half of the approximately 90-km2 14

[56-mi2 15 ] Lance District, an area where the Applicant is actively exploring to determine whether 

16 there are additional uranium deposits. As Figure 2.2 shows, Strata has also identified four other 

17 uranium-bearing areas that would extend the area of uranium recovery to the north with the 

18 Ross Amendment Area 1 and to the south of the Lance District with the Kendrick, Richards, and 

19 Barber satellite facilities (Strata, 2012a).

20

21 The Lance District is located on the western edge in the northwest corner of the Nebraska-North 

22 Dakota-Wyoming Uranium Milling Region (NSDWUMR) (see Figure 2.3). It is situated between 

23 the Black Hills uplift to the east and the Powder River Basin to the west (Strata, 2011a). Both of 

24 these regional features are described in the GEIS (NRC, 2009). However, the Powder River 

25 Basin has been described as part of the Wyoming East Uranium Milling Region (WEUMR) and 

26 the Black Hills uplift as part of the NSDWUMR. The uranium ore zone at the Ross Project is 

27 situated in the upper Cretaceous Fox Hills and Lance Formations. Although these stratigraphic 

28 units are not specifically described in the GEIS, they share key attributes that are important for 

29 ISR with the uranium-hosting Wasatch Formation in the Powder River Basin described for the 

30 WEUMR and the Inyan Kara Group described for the NSDWUMR (NRC, 2009). These key 

31 attributes include alternating layers of sandstone, which allow hydraulic circulation, and shale, 

32 which prevent hydraulic circulation. The environment of the Proposed Action is described in 

33 Section 3 of this SEIS.

34

35 The Proposed Action includes the ISR facility itself and its wellfields (see Figures 2.4 and 2.5). 

36 The ISR facility consists of the following:

37

38 ■ A CPP that houses the uranium- and vanadium-processing equipment, drying and 

39 packaging equipment, and water-treatment equipment.

40 ■ A chemical storage area as well as other storage, warehouse, maintenance, and 

41 administration buildings.

42 ■ Two double-lined surface impoundments, a sediment impoundment, and five Class I deep43 injection wells.

44

45 The schedule for the Proposed Action is shown in Figure 2.6. The Proposed Action includes the 

46 option of the Applicant’s operating the Ross Project facility beyond the life of the Project’s 

47 wellfields. 
DRAFT In Situ Uranium Recovery and Alternatives

2-4

1

2

Figure 2.2

Potential Satellite Areas in the Lance District

Source: Strata, 2012a.
DRAFT In Situ Uranium Recovery and Alternatives

2-5

1

2

Figure 2.3

Nebraska-South Dakota-Wyoming Uranium Milling Region

Source: NRC, 2009
DRAFT In Situ Uranium Recovery and Alternatives

2-6

1

2

Figure 2.4

Proposed Ross Project Facility and Wellfields

Source: Strata, 2011b.
2-7

1

Figure 2.5

General Layout of Proposed Ross Project Facility

Source: Strata, 2012a.
DRAFT In Situ Uranium Recovery and Alternatives

2-8

1

Figure 2.6

Schedule for Potential Lance District Development

Source: Strata, 2012a.
DRAFT In Situ Uranium Recovery and Alternatives

2-9

1 The facility could be used to process uranium-loaded resins from satellite projects within the 

2 Lance District operated by the Applicant, or from other offsite uranium-recovery projects not 

3 operated by the Applicant, or from offsite water-treatment operations. In this case, the life of the 

4 facility would be extended to 14 years or more (Strata, 2012a). 

5

6 The Ross Project would host 15 – 25 wellfield areas and would consist of a total of 1,400 –

7 2,000 recovery and injection wells (Strata, 2011a). Groups of wells (“well modules”) within a 

8 wellfield would be connected with piping to a central collection facility called a “module building,” 

9 or a “header house.” The wellfields would also be surrounded by a perimeter ring of monitoring 

10 wells.

11

12 This type of uranium extraction, in situ uranium recovery, consists of water to which chemicals 

13 have been added, referred to as “lixiviant,” that is injected into the aquifer 

14 bearing the uranium ore (the “ore zone” or 

15 “ore body”) (see Section 2.1.1.2). The 

16 chemicals in the lixiviant dissolve the 

17 uranium from the rock within the aquifer. 

18 Ground water containing dissolved uranium 

19 is then pumped from the ore-zone aquifer, 

20 processed through ion-exchange (IX) 

21 columns to remove the uranium from the 

22 lixiviant, and then the uranium is precipitated into a solid material called “yellowcake” (U3O8). 

23 Most of the water is then reused for uranium recovery.

24

25 ISR is not hydraulic fracturing or “hydrofracking.” Hydrofracking is a technique that is used by 

26 oil companies to increase the production of petroleum and natural gas by creating cracks in tight 

27 rocks containing oil and gas. A hydraulic fracture is formed by a fracturing fluid that is pumped 

28 into a well at a rate sufficient to increase pressure in the well, so that it exceeds the in situ 

29 pressure of the rock. The fracturing fluid is a slurry of water, chemicals to aid in cracking, and a 

30 proppant, a material such as sand grains or ceramic particulates that keep the fractures open 

31 when the injection is stopped and oil recovery occurs. In contrast, ISR operates at much lower 

32 pressure in the injection well. In situ pressures in ISR injection wells are only slightly above the 

33 in situ aquifer pressure. In addition, ISR is only used in aquifers with sufficient porosity and 

34 permeability to allow water flow from an injection well with a slightly positive pressure to the 

35 recovery well with a slightly negative pressure. This difference in pressure causes the ground 

36 water to move toward the recovery well. Finally, the chemicals in the water injected in ISR are 

37 for the purpose of dissolving the uranium, not to affect the porosity or permeability of the rock as 

38 are those during hydrofracking.

39

40 The Ross Project would be located in Crook County, Wyoming, 35 km [22 mi] north of the town 

41 of Moorcroft and Interstate-90 (see Figure 2.1). Other nearby towns and approximate direct 

42 distances to the Ross Project area include Pine Haven (27 km [17 mi] southeast), Gillette (53 

43 km [33 mi] southwest), and Sundance (48 km [30 mi] southeast). The Ross Project area is 

44 adjacent to the unincorporated ranching community of Oshoto. The Oshoto community includes 

45 11 residences within 3.2 km [2 mi] of the Proposed Action’s boundary. Access to the Ross 

46 Project area is by either County Road (CR) 68 (D Road) or CR 164 (New Haven Road), both of 

47 which proceed north. 

48

49 The Ross Project encompasses approximately 697 ha [1,721 ac] in portions of Sections 7, 17, 

50 18, and 19, Township 53N, Range 67 West, and portions of Sections 12, 13, and 24, Township 

51 53N, Range 68 West. 

What is lixiviant?

A solution composed of native ground water and 

chemicals added during the ISR operations. Lixiviant is 

then pumped underground to mobilize (dissolve) 

uranium from a uranium-bearing ore zone, or the ore 

body.
DRAFT In Situ Uranium Recovery and Alternatives

2-10

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

1819202122

23

24 Source: Table 1.2-1 in Strata, 2011a.

25

26 Surface ownership within the Ross Project area is primarily private, with small tracts of land 

27 owned by the State of Wyoming and the BLM (Strata, 2011a). Approximately 16 ha [40 ac] are 

28 BLM land. The Wyoming Office of State Lands and Investments (WOSLI) administers 127 ha 

29 [314 ac]. In addition to the surface ownership, the BLM manages the subsurface mineral rights 

30 under 65 ha [160 ac] of privately owned land. Table 2.1 indicates the respective landowners of 

31 the Ross Project area. Current land uses are discussed in Section 3.2.

32

33 The Ross Project area is located in the upper reaches of the Little Missouri River, which flows 

34 northeasterly into southeastern Montana, through northwest South Dakota, and into North 

35 Dakota where it empties into the Missouri River at Lake Sakakawea. The area is characteristic 

36 of northwestern Wyoming: It is sparsely populated rangeland used primarily for grazing and 

37 some dry-land agricultural production. Oil development from the Minnelusa Formation in 

38 western Crook County began in the 1970s. There are three oil-recovery wells within the Ross 

39 Project area; oil production from these wells peaked in 1985 – 1986, but production has 

40 generally declined since then (Strata, 2011a).

41

42 As noted earlier, uranium targeted for production within the Ross Project is located in permeable 

43 sandstones of the Upper Cretaceous Lance and Fox Hills Formations. The uranium in the 

44 Oshoto area resides in roll-front deposits typical of those across the Powder River Basin as 

45 described in the WEUMR (NRC, 2009). Roll fronts are formed in sandstone formations when 

46 uranium-bearing ground water, moving down-gradient, encounters changing conditions. As the 

47 aquifer changes from oxygenated to oxygen-deficient, uranium precipitates as a coating on 

48 sand grains. The precise geometry of the uranium-ore deposits is controlled by the site-specific 

49 characteristics of the host sandstones. At the Ross Project area, the ore zones are generally 

50 thicker and more massive in the deeper Fox Hills compared to the deposits in the Lance 

51 Formation (Strata, 2011a). 

52

53 Exploration of uranium deposits in the Lance Formation began in late 1970 (Strata, 2011a). The 

54 Nubeth Joint Venture (Nubeth), a joint venture between Nuclear Dynamics (later named ND 

55 Resources, Inc.) and Bethlehem Steel, received a License to Explore (No. 19) from the 

56 Wyoming Department of Environmental Quality’s (WDEQ’s) Land Quality Division (LQD) in 

Table 2.1

Surface Ownership at Ross Project Area

Surface 

Ownership

Total Acres 

within Ross 

Project Area

Acres 

Disturbed 

During Year 

Preceding 

Operation

Acres 

Disturbed 

Over Life of 

Proposed 

Action

U.S. Bureau 

of Land 

Management

40.0 1.3 1.3

State of 

Wyoming 314.1 40 80

Private 1,367.2 69 199

TOTAL 1,721.3 110.3 280.3
DRAFT In Situ Uranium Recovery and Alternatives

2-11

1 August 1976, with subsequent modifications to accommodate research and development 

2 activities in 1978 (Strata, 2011a). ND Resources, Inc. filed for an NRC source materials license 

3 in November 1977, and the license was approved in April 1978. Nubeth constructed a research 

4 and development operation in Section 18 of Township 53 North, Range 67 West, which is 

5 located within the Ross Project area (see Figure 2.1). 

6

7 The research and development operation consisted of a single five-spot well pattern, with four 

8 injection wells and one recovery well, and a small facility with an IX, elution, and precipitation 

9 circuit capable of producing yellowcake slurry. The research and development facility could 

10 process 340 L/min [90 gal/min] of uranium-bearing lixiviant. Hydraulic control during the 

11 operation was accomplished with “buffer” wells, which were meant to form a hydraulic barrier to 

12 keep the lixiviant within the well pattern. Nubeth operated from August 1978 through April 1979 

13 and recovered small amounts of uranium. No precipitation of a uranium product took place, and 

14 all of the recovered uranium was stored as a solution. After uranium-recovery tests were 

15 completed, the single five-spot used in the test was restored. Restoration was completed in 

16 February 1983 and Nubeth was notified by the WDEQ on April 25, 1983 that the restoration was 

17 satisfactory. Final approval for the research and development project’s final operation 

18 decommissioning was granted by the NRC and WDEQ/LQD during the time period from 1983 

19 through 1986 (Strata, 2011b). 

20

21 Undesirable plugging of the aquifer, which was attributed to the build-up of fine particles, 

22 restricted injection rates and eventually led to the Nubeth operation’s premature shutdown. A 

23 summary report on production feasibility estimated that uranium production could average about 

24 360 kg/d [800 lb/d] in a facility sized to process 11,000 – 15,000 L/min [3,000 – 4,000 gal/min] 

25 (Strata, 2011a). However, due to the declining price of uranium at the time, commercial-scale 

26 licensing, construction, and operation did not occur. Two of Nubeth’s wells (Well Nos. 789V and 

27 19XX) have been used by oil companies since 1980 (Strata, 2011b); currently, the Merit Oil 

28 Company (Merit) is operating these two wells in addition to one more on the Ross Project area.

29

30 The Applicant notes that information obtained from the Nubeth research and development 

31 project was used in its decision to develop the Ross Project at the location described in this 

32 SEIS (Strata, 2011a). Nubeth’s operation contributed the following information:

33

34 ■ Demonstration of the probability of an aquifer exemption of the mineralized zone

35 ■ Determination of strong geologic confinement above and below the identified ore body(ies)

36 ■ Confirmation of fundamental hydrogeologic hypotheses regarding ground-water flow and 

37 behavior

38 ■ Validation of information on potential regulatory and operational technical issues

39 ■ Determination of site geology, hydrology, soils, ecology, climate, and background 

40 radiological conditions

41 ■ Decrease of disturbance to both the surface and subsurface based on data collected in the 

42 past

43 ■ Demonstration of successful ground-water restoration and site reclamation 

44

45 Peninsula Energy Ltd. (formerly Peninsula Minerals Ltd.) initiated acquisition of mineral rights in 

46 the Lance District in 2007 and 2008 (Peninsula, 2011). Exploration drilling programs, which 

47 were conducted in 2008 and 2009, confirmed significant uranium resources in the Ross Project 

48 area. Strata was incorporated in 2009; in 2010, Strata submitted applications for an NRC 
DRAFT In Situ Uranium Recovery and Alternatives

2-12

1 combined source and byproduct materials license, a Permit to Mine to WDEQ/LQD, and a POO 

2 to BLM. WDEQ/LQD approved Strata’s Permit to Mine application in November 2012. The 

3 BLM is currently reviewing Strata’s application, as is the NRC through the development of this 

4 SEIS and its SER. BLM is participating as a “cooperating agency” to the NRC under a 

5 Memorandum of Understanding (MOU) for the Ross Project.

6

7 In Section 2 of the GEIS, the four stages in the life of an ISR facility are described: 1) 

8 construction, 2) operation, 3) aquifer restoration, and 4) decommissioning (NRC, 2009). The 

9 decommissioning phase would include facility decontamination, dismantling, demolition, and 

10 disposal as well as site reclamation and restoration. Although NRC recognizes that these four 

11 phases could be performed concurrently, and in practice early wellfields would undergo aquifer 

12 restoration while other wellfields are being installed, the GEIS determined that describing the 

13 ISR process in terms of these stages aids in the discussion of the ISR process and in the 

14 evaluation of potential environmental impacts from an ISR facility. 

15

16 2.1.1.1 Ross Project Construction

17

18 Construction of the Ross Project would be consistent with the general construction activities 

19 described in Section 2.3 of the GEIS (NRC, 2009). The Applicant discusses certain 

20 preconstruction activities that could be performed prior to its receiving a license from the NRC 

21 (Strata, 2011a); however, for the purposes of this evaluation of environmental and other 

22 impacts, this SEIS assumes that these preconstruction activities would occur at the same time 

23 as the Proposed Action such that the impacts of the preconstruction activities are considered as 

24 part of Alternative 1: Proposed Action. These preconstruction activities could include site 

25 excavation and preparation, such as clearing, grading, and constructing design components 

26 intended to control drainage and erosion as well as other mitigation measures; erection of 

27 fences and other access control measures that are not related to the safe use of, or security of, 

28 radiological materials; support-building construction; infrastructure construction, such as paved 

29 roads and parking lots, exterior utility and lighting systems, domestic-sewage facilities, and 

30 transmission lines; and other activities which have no measurable relationship to radiological 

31 health and safety nor common defense and security. In addition, the Applicant has indicated its 

32 intent to construct one Class I deep-injection well to better characterize the hydrologic and 

33 geochemical properties of the targeted geologic formation (i.e., ore zone) (Strata, 2011a). No 

34 radioactive materials would be present at the Ross Project during preconstruction activities. 

35

36 After some or all of these activities, actual construction of the Proposed Action would begin and 

37 include: 1) the ISR facility that would consist of the CPP as well as administration, warehouse, 

38 and maintenance buildings, including storage and other structures, and lined surface 

39 impoundments; 2) wellfields including piping and module buildings; and 3) deep-disposal wells 

40 (see Figure.2.5) (Strata, 2011b; Strata, 2012b).

41

42 The Applicant anticipates construction of the facility and initial wells within one year of receiving 

43 an NRC license (see Figure 2.6). Main access roads would be constructed at the same time as 

44 the facility (Strata, 2011a). Secondary wellfield access roads would be constructed as 

45 necessary, as each wellfield is developed. It is estimated that the facility would encompass 21 

46 ha [51 ac] (Strata, 2011b). A total of 44 ha [110 ac] would be disturbed by construction activities 

47 during the year preceding ISR facility operation and 113 ha [280 ac] over the life of the 

48 Proposed Action (see Table 2.1) (Strata, 2011a).

49

50 The Ross Project would employ approximately 200 people during construction. The Applicant 

51 anticipates that most employees would be from Crook and Campbell Counties (Strata, 2011a). 
DRAFT In Situ Uranium Recovery and Alternatives

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1 Further information on employment and other socioeconomic issues are described in Section 

2 3.11.

3

4 Ross Project Facility

5

6 The Applicant proposes to construct and operate a single facility to serve the Ross Project as 

7 well as other potential ISR satellites (i.e., wellfields) within the Lance District. It could also 

8 process uranium-loaded resins from other ISR and water-treatment operations, which would be 

9 trucked into the facility (Strata, 2011a). The facility would include an administration building of 

900 m2 [10,000 ft2

], 1,400 m2 [15,000 ft2] of warehouse and maintenance space, 1,800 m2 10

[20,000 ft2

] of parking, and a 3,400 m2 [37,000 ft2 11 ] for a domestic waste-water drainfield as well 

12 as the CPP mentioned earlier.

13

The proposed CPP would be a large, 6,900 m2 [74,000 ft2 14 ] pre-engineered metal building. The 

15 size of the CPP is about twice the size of a typical processing facility described in the GEIS 

(NRC, 2009). Adjoining the CPP would be 2,800 m2 [30,000 ft2 16 ] of chemical storage space and 

4,800 m2 [51,300 ft2 17 ] of storage and work space (see Figure 2.5). The CPP would contain a 

18 control room housing the master-control system to allow remote monitoring and control of ISR 

19 process operations, wellfield operations, and deep-well disposal (Strata, 2011b). Operators in 

20 the CPP control room, who would be present 24 hours a day, would use a computer-based 

21 station to command the control system.

22

23 Proposed operations in the CPP would be generally consistent with typical processing involving 

24 three primary stages as described in the GEIS (NRC, 2009; Strata, 2011b): 

25

26 ■ Uranium would be mobilized by 

27 the distribution of “barren” 

28 (containing no uranium) lixiviant 

29 from the CPP to injection wells 

30 and return of “pregnant” 

31 (containing dissolved uranium) 

32 lixiviant from the recovery wells 

33 to the CPP for processing.

34 ■ Dissolved uranium would be 

35 processed to yellowcake through 

36 a multi-step process involving IX 

37 resins, elution, precipitation, 

38 washing, drying, and packaging 

39 which would produce waste 

40 water. 

41 ■ Waste water would be treated as necessary and then recirculated as lixiviant. 

42

43 This uranium-recovery process would be continued in a particular wellfield until the uranium 

44 concentration in the recovered solution becomes uneconomical.

45

46 The IX circuit proposed by the Applicant would be designed for a maximum of 28,400 L/min 

47 [7,500 gal/min] of pregnant lixiviant from Ross Project wells (Strata, 2011a). The elution, 

48 precipitation, and drying and packaging circuits would be designed to process approximately 1.4 

49 million kg/yr [3 million lb/yr] of yellowcake (Strata, 2011b), which is about four times the capacity 

50 necessary to recovery uranium from the Ross Project. The excess capacity in the yellowcake 

What is yellowcake?

Yellowcake is the product of the uranium-recovery and milling 

process; early production methods resulted in a bright yellow 

compound, hence the name “yellowcake.” The material is a 

mixture of uranium oxides that can vary in proportion and in 

color from yellow to orange to dark green (blackish) 

depending on the temperature at which the material was dried 

(level of hydration and impurities). Higher drying 

temperatures produce a darker, less soluble material. 

Yellowcake is commonly referred to as U3O8 and is assayed 

as pounds U3O8 equivalent. This fine powder is packaged in 

208-L [55-gal] drums and sent to a conversion plant that uses 

yellowcake to produce uranium hexafluoride (UF6) as the next 

step in the manufacture of nuclear fuel.
DRAFT In Situ Uranium Recovery and Alternatives

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1 production circuit would allow processing of loaded IX resins brought to the Ross Project from 

2 other ISR or water-treatment facilities. Except for the Smith Ranch-Highland operation that has 

3 a yellowcake capacity of 2.5 million kg/yr [5.5 million lb/yr], the capacity of the Ross Project 

4 exceeds the capacity of other facilities in Wyoming, which range from 0.2 million kg/yr [0.5 

5 million lb/yr] to 0.9 million kg/yr [2 million lb/yr] (EIA, 2012).

6

7 The Applicant also proposes a vanadium-recovery circuit within the CPP to recover vanadium 

8 from uranium-depleted solutions (Strata, 2011b). The GEIS did not include vanadium recovery 

9 in its discussion of a typical uranium-recovery operation (vanadium recovery is discussed in 

10 Section 2.1.12 of this SEIS).

11

12 In addition to the uranium- and vanadium-recovery circuits, the CPP would house the water13 treatment circuit for ground-water restoration. Water treatment would utilize an IX column to 

14 remove the uranium, followed by two reverse-osmosis (RO) units in series. The circuit would be 

15 designed for a maximum flow rate of 4,200 L/min [1,100 gal/min]. Operation of the first RO 

16 stage is expected to return approximately 70 percent of the flow as “permeate” (relatively clean 

17 water) and 30 percent of the flow as “brine” (water containing high concentrations of salts, which 

18 were mostly introduced to water to form the lixiviant, and contaminants, which were picked up 

19 during the lixiviant’s residence time in the aquifer). When the remaining brine is run through the 

20 second RO stage, it would generate 50 percent permeate and 50 percent brine. Only 15 

21 percent of waste water would be brine after the two-stage RO processing.

22

23 The ISR process requires chemical storage and feeding systems to introduce chemicals at 

24 various stages in the lixiviant extraction and processing as well as during the waste-treatment 

25 processes. Space for chemical storage would be built adjacent to the CPP (see Figure 2.5) 

26 (Strata, 2011b). The chemical-storage area would be constructed with secondary containment, 

27 which will consist of a concrete berm as part of the floor area that would be able to contain at 

28 least 110% of the volume of the largest tank (Strata, 2011b). The space would be divided into 

29 two areas, one inside the CPP and one outside. Chemicals stored outside would include 

30 oxygen, ammonia, and carbon dioxide. Chemicals stored inside would include some or all of 

31 the following: sulfuric acid, hydrochloric acid, sodium hydroxide, hydrogen peroxide, sodium 

32 chloride, sodium carbonate, and barium chloride.

33

34 The proposed location for the facility is currently on a relatively flat, currently used, dry-land 

35 hayfield. To route surface storm-water runoff around the facility, a diversion structure consisting 

36 of a berm, concrete-box culvert, and drainage channel would be constructed east of the 

37 proposed ISR facility. This system would be designed to manage runoff from a 100-year, 24-

38 hour runoff event (Strata, 2011b; Strata, 2012b).

39

40 The Applicant’s design calls for paving the areas adjacent to the CPP. Paved areas would be 

41 sloped to direct runoff water to slot drains. From the slot drains, storm water would be 

42 conveyed through pipes to a smaller, sediment-settling surface impoundment also designed to 

43 contain the runoff from a 100-year, 24-hour runoff event. The sediment impoundment would be 

44 constructed with the same double-liner and leak-detection configurations as the larger surface 

45 impoundments that would be used to store permeate and brine. After a significant storm event, 

46 water in the sediment impoundment would be immediately routed to the deep-disposal well 

47 (Strata, 2011b).

48

49 The facility is proposed to be located in an area of shallow ground water (Strata, 2012b). 

50 Shallow ground water directly beneath the facility could present construction and operational 

51 issues and create a higher risk of ground-water contamination in the event of a spill. To mitigate 
DRAFT In Situ Uranium Recovery and Alternatives

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1 these concerns, the Applicant’s proposed facility design would include a containment barrier 

2 wall (CBW). The CBW and associated dewatering system would be designed to prevent 

3 contaminated liquids from entering and contaminating shallow ground water outside of the 

4 facility, in the event of a process solution spill, hazardous-chemical spill, or a disposal-system 

5 failure. The CBW would restrict the flow of ground water from traveling beneath the facility and 

6 any water that seeps or flows into the area would be drained away. The design calls for the 

7 CBW to be constructed around approximately two-thirds of the facility’s boundary along the 

8 north, east, and south. The CBW would be 0.7 m [2 ft] wide and extend from the ground 

9 surface to a minimum of 0.7 m [2 ft] into bedrock. It would be constructed of a soil-bentonite 

10 mixture. The configuration of the CBW is shown in Figure 2.5 and is described in Addendum 

11 3.1-A of the TR (Strata, 2012b). Three French drains (i.e., trenches filled with very porous 

12 material, such as gravel) would be installed to drain the area within the CBW, when needed 

13 (Strata, 2011b; Strata, 2012b). The Applicant proposes approximately eight wells to monitor 

14 water levels and water quality inside and outside the CBW (Strata, 2012b). Any seepage and/or 

15 spillage collected on the facility side of the CBW would be discharged to the surface 

16 impoundments for storage or disposal with excess permeate and brine (Strata, 2011b). 

17 Construction of a CBW to mitigate impacts to shallow ground water beneath impoundments is 

18 not included in the GEIS’s description of a typical ISR facility design (NRC, 2009).

19

20 The Proposed Action would also include the construction of two double-lined surface 

21 impoundments (retention ponds) over a 6.5 ha [16 ac] area; these impoundments would be 

22 used for process-solution and waste-water management (Strata, 2011b). Each surface 

23 impoundment would include three cells, built with common containment berms. At full capacity 

24 the impoundments’ surface area would be about 5.3 ha [13.2 ac]. Interconnected pipes 

25 between the cells would allow the controlled transfer of solutions or water between cells. The 

26 impoundments would have double geomembrane liners and a leak-detection system. The 

27 design for the impoundment, including the liners, leak-detection systems, freeboard 

28 requirements, and reserve capacity are in accordance with the GEIS, but the size of the 

29 impoundments is about twice the upper range of typical surface impoundment sizes described 

30 in the GEIS (NRC, 2009). 

31

32 The surface impoundments would be designed to meet the requirements of NRC Regulatory 

33 Guide 3.11 (NRC, 1980a), all conditions established by the NRC in the Applicant’s license, and 

34 all requirements found in Wyoming Water Quality Rules and Regulations, Chapter 11, for lined 

35 waste-water surface impoundments (Strata, 2011b; Strata, 2012b; WDEQ/WQD, 1984). 

36

37 The Applicant’s surface-impoundment design calls for rectangular cells with maximum internal 

38 slopes of 3 horizontal to 1 vertical (Strata, 2011b; Strata, 2012b). The impoundments would be 

39 4.6 m [15 ft] deep with 1 m [3 ft] of freeboard and a maximum hydraulic depth of 3.6 m [12 ft]. 

40 The primary liner would be impermeable high-density polyethylene (HDPE) or polypropylene, 

41 with a minimum thickness of 36 mils (0.9 mm [0.036 in]). The secondary liner would be a 

42 geosynthetic material with a minimum thickness of 36 mils (0.9 mm [0.036 in]) or native clay. 

43 The leak-detection system would be installed between the primary and secondary liners. The 

44 system would consist of a permeable drainage layer such as sand and perforated collection 

45 pipes. 

46

47 The primary purpose of the surface impoundments would be to manage liquid, byproduct 

48 material (i.e., the permeate and brine described above) to optimize disposal techniques, and to 

49 provide capacity for liquid-waste storage in the event of “upset,” or accident, conditions. In 

50 addition, the impoundments would provide some evaporation of stored brine. Under normal 

51 operating conditions, the water levels in the surface-impoundment cells would be maintained 
DRAFT In Situ Uranium Recovery and Alternatives

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1 such that the volume of liquid in any one cell can be transferred to one of the other two cells to 

2 facilitate leak repair.

3

4 Ross Project Wellfields

5

6 Wellfields are the areas over the ore zone(s) where the injection and recovery wells for uranium 

7 recovery would be located. The proposed wellfields of the Ross Project are expected to 

8 encompass approximately 36.4 ha [90 ac] in portions of Sections 7, 17, 18, and 19, in Township 

9 53N, Range 67W and in portions of Sections 12 and 13 in Township 53N, Range 68W. The 

10 Applicant notes that the final areal extent of the constructed wellfields is expected to be greater 

11 as additional ore-zone delineation occurs (Strata, 2011b).

12

13 The proposed wellfields would be divided into two units (Strata, 2011b). Each unit would be 

14 further divided into 15 to 20 modules with approximately 40 recovery wells per wellfield module 

15 (Strata, 2011b). The flow capacity of each wellfield module would range from 2,300 L/min [600 

16 gal/min] to 3,800 L/min [1,000 gal/min]. The wellfields would be fenced to exclude livestock, 

17 wildlife, and other intruders.

18

19 Wells would be constructed to recover uranium from ore deposits found in permeable sand 

20 zones in stacked roll fronts and tabular ore zones described as “stratabound” deposits in the 

21 GEIS (NRC, 2009). The geology of the ore zone at the Ross Project area is described in SEIS 

22 Section 3.4.1. The average depth to the top of the ore zone ranges from less than 91 m [300 ft] 

23 to more than 213 m [700 ft] with an average depth of 149 m [490 ft] (Strata, 2011b). The ore24 zone thickness averages 2.7 m [8.9 ft]. The sand units hosting uranium are saturated with 

25 ground water and are confined aquifers (Strata, 2011b). The hydrogeology of this area is 

26 described in SEIS Section 3.5.3.

27

28 The features and design of the wellfields proposed by the Applicant are generally consistent 

29 with the wellfields described in the GEIS (NRC, 2009). The primary components of a wellfield 

30 module are illustrated in Figure 2.7; these are:

31

32 ■ Injection wells to introduce lixiviant into the ore zone.

33 ■ Production (or recovery) wells to recover the uranium-enriched (or pregnant) lixiviant for 

34 subsequent processing at the CPP.

35 ■ Module buildings (or header houses) to manage the pipes (or “flow lines”) that route the 

36 lixiviant between the injection and recovery wells within a module and the “feeder lines” that 

37 carry fluids between the module building to a manhole containing a valve.

38 ■ Valve manholes to manage the pipes to the module buildings, to the CPP, and to other 

39 value manholes (or “trunk lines”).

40 ■ Perimeter monitoring wells to detect excursions of lixiviant outside the exempted portion of 

41 the aquifer from which uranium is recovered, should they occur.

42

43 The Applicant proposes three well-construction methods that would each comply with 

44 WDEQ/LQD requirements (see Figures 2.8, 2.9, and 2.10) (Strata, 2011b). 
DRAFT In Situ Uranium Recovery and Alternatives

2-17

1

Figure 2.7

Primary Components of a Ross Project Wellfield Module

Source: Strata, 2011a.
2-18

Figure 2.8

Proposed Well-Installation Method 1 for Ross Project Injection and Recovery Wells

1 Source: Strata, 2012a.
2-19

Figure 2.9

Proposed Well-Installation Method 2 for Ross Project Monitoring Wells

1 Source: Strata, 2012a. So
2-20

1

Figure 2.10

Proposed Well-Installation Method 3 for Ross Project Monitoring Wells

Source: Strata, 2012a.

Source: Strata
DRAFT In Situ Uranium Recovery and Alternatives

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1 These methods all conform to the typical well-completion standards described in the GEIS 

2 (NRC, 2009). Wells would be constructed of polyvinyl chloride (PVC) or fiberglass with a 

3 sufficient pressure rating to withstand the maximum anticipated injection pressure, the 

4 maximum external collapsing pressure, and the maximum pressure of cementing; they would be 

5 constructed in accordance with WDEQ rules (WDEQ/LQD, 2005). The casings would be joined 

6 using an O-ring and spline modified to fit the ore zone, and well spacing would range from 15 –

7 46 m [50 – 150 ft]. The Applicant proposes that wells configured in a line-drive pattern would 

8 likely require increased aquifer restoration efforts; therefore, the Applicant would make limited 

9 use of line-drive patterns. Where it is not possible to avoid the use of line-drive patterns, the 

10 Applicant would perform additional computer modeling to determine the most efficient well 

11 spacing so as to facilitate aquifer restoration.

12

13 The Underground Injection Control (UIC) program administered by WDEQ/LQD regulates the 

14 design, construction, testing, and operation of all injection and recovery wells (WDEQ/LQD, 

15 2005). WDEQ has primary regulatory authority for such actions as delegated by the U.S. 

16 Environmental Protection Agency (EPA). Wells for uranium extraction are classified under the 

17 UIC program as Class III wells; the Proposed Action would therefore require a UIC permit from 

18 WDEQ to use Class III injection wells. Before ISR operations could begin at any wellfield, the 

19 Applicant would be required by a license condition to provide the NRC with documents clearly 

20 delineating the approved aquifer exemption areas. (Portions of the aquifers designated for 

21 uranium recovery must be exempted as an underground source of drinking water [USDW] by 

22 EPA and reclassified by WDEQ/Water Quality Division (WQD) in accordance with the Safe 

23 Drinking Water Act [SDWA].)

24

25 Consistent with the typical design described in the GEIS (NRC, 2009), the Applicant proposes 

26 that each wellhead would be covered by an insulated fiberglass box in order to provide freeze 

27 protection and spill containment (Strata, 2011b). The protective box would include a solid base 

28 with access tunnels for well casing, electrical, and water-flow lines as well as a leak-detection 

29 system. Each recovery well would contain a submersible pump properly sized to carry solutions 

30 from the well to the module building. Injection wells would be equipped with air-release valves 

31 to permit relief of any excess pressure that could occur in the wells.

32

33 In the event that recovery, injection, and/or monitoring wells must be located within a floodplain, 

34 engineered controls and instrumentation would act to prevent leakage to the environment or 

35 contamination to the wells from a flood event (Strata, 2011b). The well seals would prevent 

36 inflow of flood waters down the well casing, while the fiberglass structure and bottom 

37 containment feature would limit exposure of the well to the environment. Erosion-control 

38 measures, such as rip-rap, grading, contouring, and water bars, would be utilized where 

39 appropriate in order to reduce sediment mobilization and runoff velocities. 

40

41 Following installation, the well would be “developed” by pumping, air lifting, jetting, and/or 

42 swabbing to clean it and improve its hydraulic efficiency. The goal of these activities would be 

43 to remove drilling fluids and any small, fine particles from the well-completion zone, to provide 

44 good hydraulic communication, and to maintain the natural geochemical conditions. The 

45 Applicant expects that the water produced during well development would meet Wyoming’s 

46 temporary Wyoming Pollution Discharge Elimination System (WYPDES) discharge standards, 

47 which would allow this water to be discharged directly to the ground surface (WDEQ/WQD, 

48 2007).
DRAFT In Situ Uranium Recovery and Alternatives

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1

2 Prior to operation, the integrity of each 

3 well would be verified by a pressure4 based mechanical-integrity testing 

5 (MIT) that conforms to the procedure 

6 described in the GEIS and required by 

7 WDEQ (NRC, 2009; Strata, 2011b; 

8 WDEQ/LQD, 2005). After initial testing 

9 by the Applicant, the well would be 

10 retested at five-year intervals. In 

11 addition, the MIT would be repeated if 

12 the well is entered by a drilling bit or an 

13 under-reaming tool, or if well damage is 

14 suspected for any reason. The well15 integrity test results would be 

16 documented and filed onsite and 

17 provided to WDEQ/LQD on a quarterly 

18 basis. 

19

20 The Applicant proposes that MIT be 

21 conducted by placing inflatable packers 

22 or a comparable device near the top of 

23 the casing and above the screened 

24 interval (Strata, 2011b). The packers 

25 are inflated, and the interval between the packers is pressurized with water to the designated 

26 test pressure (maximum allowable injection pressure plus a safety factor of 25 percent). This 

27 pressure must be maintained within 10 percent for 10 minutes in order for the well to pass the 

28 MIT. A well-integrity record would be completed for each tested well. If a well demonstrates an 

29 unacceptable pressure drop during the MIT, the packers would be reset, the equipment checked 

30 for leaks, and the test repeated. If in subsequent tests the well passes the integrity 

31 requirements, the well would be deemed acceptable for use as an injection, recovery, or 

32 monitoring well. If a well continues to fail the MIT, it would be plugged and properly abandoned

33 (i.e., sealed with cement slurry). Any well excluded due to MIT failure, or any that have arrived 

34 at the end of their useful life, would be properly abandoned. A well-abandonment record would 

35 be completed and retained onsite until the termination the Applicant’s license, as would be 

36 required in NRC’s license.

37

38 The Applicant’s proposed design for pipes and module buildings is consistent with the industry 

39 standard described in the GEIS (NRC, 2009). Module buildings (referred to as pump and 

40 header houses in the GEIS) would be located throughout the wellfield and would be 

41 approximately 4.6 m x 12.2 m [15 ft x 40 ft] in size (see Figure 2.7) (Strata, 2011b). Piping from 

42 the module building to the CPP is referred to as feeder lines and trunk lines. Flow to injection 

43 wells and from recovery wells would be conveyed through 2.5 – 5 cm [1 – 2 in] HDPE pipelines 

44 (flow lines) that are connected through a manifold in the module building. Pipes inside the 

45 module buildings would be HDPE, PVC, or stainless steel rated for an operating pressure 

46 greater than the proposed maximum injection pressure. Feeder-line and trunk-line junctions 

47 would be contained in valve manholes located along the trunk lines. Each module building 

48 would have the capability of being isolated from the trunk lines by manually operated butterfly 

49 valves contained in the valve manholes. Piping would be buried below the frost line.

What is mechanical integrity testing (MIT)?

After each well is completed, and before the well is brought 

into service, all injection and recovery wells are tested for 

mechanical integrity. A “packer” is set above the well 

screen, and the well casing is filled with water. At the 

surface, the well is pressurized with either air or water to

125 percent of the maximum operating pressure, which is 

calculated based upon the strength of the casing material 

and depth. The well pressure is monitored to ensure 

significant pressure drops do not occur through drillhole 

leaks. A pressure drop of no more than 10 percent in a 

period of 10 to 20 minutes indicates that the casing and 

grout are sound (i.e., do not leak) and that the well is fit for 

service. Well integrity tests are also performed if a well 

has been damaged by nearby surface or subsurface

activities or has been serviced with equipment or 

procedures that could damage the well casing, such as 

insertion of a drill bit or cutting tool. Additionally, each well 

is retested periodically (once each 5 years or less) to 

ensure its continued integrity. If a well casing fails an MIT, 

the well is taken out of service, repaired, and retested. If 

an acceptable test cannot be obtained after repairs, the 

well is plugged and properly abandoned.
DRAFT In Situ Uranium Recovery and Alternatives

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1 Each well flow line would have a meter to record the total flow passing through each flow line, 

2 pressure transmitter, and manual valve to control the flow rate. A small sample-collection valve 

3 for each well would be included on the recovery flow lines. The recovery-well flow lines would 

4 enter a manifold on one side of the module building, and the injection well lines would enter a 

5 manifold on the other side. A manifold building would house: 1) electrical equipment required to 

6 control the recovery pumps; 2) a pressure-limiting valve, a pressure transmitter, and equipment 

7 to add the oxidant to lixiviant on the injection manifold; and 3) flow meters that would indicate 

8 rate and totalizer readings on the trunk lines (Strata, 2011b). Each module building would have 

9 a manhole to access flow lines and feeder lines (see Figure 2.7). The manholes would also 

10 contain leak-detection systems. 

11

12 The Applicant would test for leaks with fresh water on the pipelines prior to their burial, in order 

13 to ensure the pipelines’ mechanical integrity (Strata, 2011b). The tests would be conducted in 

14 accordance with the manufacturer’s recommendations or industry standards prior to final burial. 

15 In the event of leakage from pipelines or fittings, the defective component would be replaced. 

16 Prior to backfilling the trench dug to install a pipeline, the Applicant would perform a final 

17 inspection of all pipes and valves, the quality of the pipe embedment material, and the suitability 

18 of the backfill. Pipeline installation and trench backfilling would follow standard procedures that 

19 would be designed to ensure the quality of the installation and backfilling (Strata, 2011b). 

20 These procedures include the Applicant:

21

22 ■ Laying of pipe at required grades and lines

23 ■ Minimizing accumulation of water during laying or backfilling

24 ■ Limiting lateral displacement with use of embedment material

25 ■ Preventing contamination of the trench with foreign, unsuitable material

26 ■ Covering pipe with at least 0.6 – 2 m [2 – 6 ft] of material

27 ■ Using insulated tracer wire and warning tape

28 ■ Using properly sized and placed bedding material

29 ■ Using proper backfill material, which would not impose undue shock or unbalance to the 

30 pipe (i.e., frozen soils, mud, or snow)

31 ■ Using trench plugs at the appropriate spacing, particularly at or near areas of elevated 

32 ground water
DRAFT In Situ Uranium Recovery and Alternatives

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1 As NRC license 

2 conditions would require, 

3 the Applicant would 

4 install a monitoring-well 

5 ring around the 

6 perimeter of each 

7 wellfield that would be 

8 used to detect horizontal 

9 and vertical excursions 

10 of uranium-recovery 

11 solutions during ISR 

12 operations (see SEIS 

13 Section 2.1.1.2) (Strata, 

14 2011b). Prior to 

15 commencing ISR 

16 operations, these wells 

17 would allow sampling 

18 and analysis of ground 

19 water and, in this SEIS, 

20 this type of monitoring is 

21 called “post-licensing, 

22 pre-operational.” The 

23 resulting post-licensing,

24 pre-operational data 

25 would be used to 

26 determine

27 concentration-based levels that would permit identification of any excursions from the respective 

28 wellfields; these would be called the Ross Project’s upper control limits (UCLs). These post29 licensing, pre-operational baseline values would be established for each separate wellfield (and 

30 they would be codified in the Applicant’s NRC license). During uranium-recovery wellfield 

31 operation, the Applicant would then sample ground water from the wells and compare the 

32 analytical values to the NRC-specified baseline constituent concentrations to determine whether 

33 an excursion of any solution (such as lixiviant) into the surrounding aquifers has occurred. The 

34 Applicant would use Methods 2 or 3 (shown in Figures 2.9 and 2.10) to install these ground35 water monitoring wells. 

36

37 The Applicant’s site-characterization efforts, which were conducted prior to its license38 application submittal to the NRC, established “pre-licensing baseline” values of certain ground39 water constituents; these values represent the baseline constituent concentrations currently 

40 present in the ground water under the Ross Project area (Strata, 2011a; Strata, 2011b). (See 

41 the text box above.) Later, prior to actual uranium-recovery wellfield operation, but after the 

42 initial NRC license is issued for wellfield construction, the ground water in each wellfield would 

43 be analyzed for the post-licensing, pre-operational baseline concentrations of constituents 

44 specified by the NRC (NRC, 2003a). 

45 Within each wellfield, the well spacing that the Applicant proposes is in accordance with the 

46 minimum requirement described in the GEIS as necessary to detect excursions (NRC, 2009). 

47 Typical well spacing for a five-spot or seven-spot pattern is between 12 and 50 m [40 and 150 ft] 

48 apart. Wells completed in the aquifer underlying the ore body and wells completed in the 

What are pre-licensing baseline water-quality concentrations?

Prior to the submittal by an Applicant of its license application to the NRC, an 

Applicant performs site-characterization environmental-monitoring efforts for 

at least a year at the site at which it wishes to conduct uranium recovery prior 

to major Project construction. 10 CFR Part 40, Appendix A, Criterion 7 

requires this monitoring (10 CFR Part 40). In addition, other regulations, such 

as those promulgated by the U.S. Environmental Protection Agency (e.g., 40 

CFR Part 192, 40 CFR Part 141, and 40 CFR Part 143) and/or pertinent 

authorized State regulations, such as Wyoming Department of Environmental 

Quality’s Hydrology Guidelines for Permitting Mines, Appendix 1, Pre-mining 

Water Quality Sampling in the Guideline No. 8 may also inform an Applicant’s 

environmental-monitoring strategies (WDEQ/LQD, 2005). Finally, NRC’s

guidance, Regulatory Guide 4.14, also makes recommendations regarding 

environmental monitoring efforts.

As part of site-characterization efforts, ground-water monitoring wells are 

installed and ground-water samples are obtained. These samples are 

analyzed for certain water-quality constituents, or parameters, that are 

important to the characterization of existing conditions at a particular site. 

These concentrations are known as the “pre-licensing baseline” values of the 

respective water-quality constituents. 

These values are also sometimes known as “background” values. However, 

in the case of the Ross Project, because an earlier uranium-recovery 

operation was conducted within the Ross Project area, this operation could 

potentially have impacted “background values.” Thus, the values measured 

by Strata prior to its submitting its license application are called “pre-licensing 

baseline” values in this SEIS.
DRAFT In Situ Uranium Recovery and Alternatives

2-25

1 aquifer overlying the ore body would be installed at an interval of one well per 0.8 ha [2 ac] of 

2 wellfield to detect vertical migration (Strata, 2011b). The Applicant also proposes a spacing of 

3 the perimeter monitoring wells of 122 m [400 ft] apart and at a distance of approximate 122 [400 

4 ft] from the edge of the wellfield, to detect potential horizontal excursions. Simulations by the 

5 Applicant demonstrate that the proposed spacing successfully detects hydraulic anomalies in 

6 the form of water-level increases well before lixiviant has moved beyond the active uranium7 recovery areas.

8

9 To reduce the possibility of lixiviant excursions, all previously drilled exploration and/or 

10 delineation drillholes that can be located on the Ross Project area and that are within a 

11 monitoring-well ring would be re-entered to each drillhole’s total depth and sealed with cement 

12 slurry, per standard well-abandonment protocols (Strata, 2011b). These historic exploration 

13 and/or delineation drillholes would be located through the use of a hand-held metal detector that 

14 would locate the brass cap associated with each drillhole with its identification number. After a 

15 drillhole is located, a small drilling rig would be set up over the hole to ream them out to their 

16 total depth. The drillholes would then be cemented from the bottom to the ground surface. 

17 Details of each drillhole’s abandonment would be documented in a record (examples in Strata, 

18 2011b, Addendum 2.7-F), which would be filed at Strata’s Oshoto field office in the appropriate 

19 drillhole file and provided with the respective wellfield 

20 data package, as appropriate. 

21

22 Deep-Injection Wells

23

24

25 The Applicant plans to dispose of 

26 liquid effluent generated during 

27 uranium-recovery operations via 

28 Class I UIC disposal wells. The 

29 Applicant has received a ten-year 

30 permit (UIC Permit No.10-263), 

31 dated April 4, 2011, for up to five 

32 Class I deep-disposal wells from 

33 WDEQ (WDEQ/WQD, 2011b). This 

34 Permit authorizes the injection of 

35 liquids into the Flathead and 

36 Deadwood Formations within 

37 specified intervals at depths of about 

38 2,488 – 2,669 m [8,163 – 8,755 ft] 

39 below the ground surface; these 

40 formations are at least 500 ft below 

41 the lowermost potential USDW (the 

42 Madison Formation). 

43

44 Under the terms of the UIC Class I 

45 Permit, the Applicant is allowed to 

46 inject into the Class I deep-disposal 

47 wells the following: operation bleed 

48 streams, yellowcake wash water,

49

What are underground injection control permits?

The EPA has delegated authority to the State of Wyoming, to 

administer its own Underground Injection Control (UIC) 

Permits. Classes I and III are most applicable to ISR

operations. 

 Aquifer Exemption: UIC criteria for the exemption of an 

aquifer that might otherwise be defined as an 

underground source of drinking water are found at 40 

CFR Part 146.4. These criteria include whether the 

aquifer is currently a source of drinking water and whether 

the water quality is such that it would be economically or 

technologically impractical to use the water to supply a 

public water system. 

 Industrial and Municipal Waste Disposal Wells (UIC 

Class I): Wells in this Class are used for the deep 

disposal of industrial, commercial, or municipal waste 

below the deepest usable aquifer. This type of well uses 

injection and requires applied pressure. This Class

includes all wells that dispose of waste on a commercial 

basis. For ISR operations, this type of UIC Permit is 

necessary to use deep-well injection for waste disposal. 

 Mining Wells (UIC Class III): This type of UIC Permit 

governs injection wells used to recover minerals. They 

include experimental technology wells; underground coal 

gasification wells; and wells for the in situ recovery of 

materials such as copper, uranium, and trona. For ISR 

operations, this type of UIC Permit covers wells that inject 

lixiviant into the uranium-bearing aquifer. 
DRAFT In Situ Uranium Recovery and Alternatives

2-26

1 sand-filter and ion-exchange wash water onsite laboratory waste water, RO brine, aquifer2 restoration ground water, facility wash-down water, wash waters used in cleaning or servicing 

3 waste-disposal-system equipment, and storm water—all generated during uranium-recovery 

4 activities—as well as fluids produced during the drilling, completion, testing, or stimulation of 

5 wells or test drillholes related to uranium-recovery operations, or during the work-over or 

6 abandonment of any such well, and drilling-equipment wash water. Under the terms of the UIC 

7 Permit, the Applicant is also prohibited from injecting certain materials into these wells. For 

8 example, hazardous wastes as defined by EPA or WDEQ cannot be injected into these wells 

9 (WDEQ/WQD, 2011b). Well construction, operation, MIT inspection, and well abandonment 

10 plugging and requirements are defined in this Permit as well. The Applicant would need to 

11 obtain written acceptance of financial-assurance methods from WDEQ prior to construction of 

12 each of the proposed wells.

13

14 The Applicant proposes that each well location would consist of a 76 m x 76 m [250 ft x 250 ft] 

15 pad with a storage tank (Strata, 2011b; Strata, 2012b). Surface equipment for the deep16 disposal wells would include storage tanks, pumps, filtration systems, instrumentation and 

17 control systems, and equipment for injection of process chemicals (Strata, 2011b). Pads would 

18 either be asphalt pavement or gravel and would be retained through the life of the disposal well 

19 in order to conduct maintenance. Access roads to well sites with widths up to 4.3 m [14 ft] 

20 would be constructed on existing roads where possible. The supply pipelines to the wells would 

21 be 15 – 25 cm [6 – 10 in] HDPE plastic.

22

23 Pressures and flow rates for the pipes and disposal wells would be constantly monitored at the 

24 CPP. Instrumentation details for the deep-disposal wells are provided in Addendum 4.2-A of the 

25 TR (Strata, 2011b). System instrumentation would provide the necessary measures to ensure 

26 safe operation of the disposal system. At a minimum, instrumentation would include a flow 

27 totalizer, flow meter, pressure regulator, pressure indicator, pressure switch, annular tank level 

28 indicator, and injection pressure chart recorder. Water quality, fluid quantity, and injection rates 

29 would be reported to the WDEQ/LQD UIC program as required by the UIC Permit.

30

31 Injection rates up to the maximum are controlled by surface-injection pressures that are limited 

32 to the fracture pressure. Exceeding the limiting surface pressure set forth in the permit or 

33 creating or propagating fractures within the receiving zone would be a permit violation. The 

34 permit requires the installation of a kill switch on the injection tubing to preclude violation of the 

35 pressure limits. 

36

37 2.1.1.2 Ross Project Operation

38

39 As shown by the proposed schedule in Figure 2.6, uranium recovery during the proposed Ross 

40 Project would follow a “phased” approach, where one group of well modules could be in 

41 operation, while preceding well modules are being engaged in aquifer restoration (Strata, 

42 2011b). During the operation phase, three major phases would occur involving the wellfields: 

43 an operation-only phase, a concurrent operation- and aquifer-restoration phase, and an aquifer44 restoration-only phase. 

45 Uranium Mobilization

46

47 The Applicant proposes the use of an alkaline lixiviant to dissolve the uranium as described in 

48 Section 2.4 of the GEIS (NRC, 2009; Strata, 2011b). Gaseous oxygen (O2) or hydrogen 
DRAFT In Situ Uranium Recovery and Alternatives

2-27

1 peroxide (H2O2) is used as the oxidant and sodium bicarbonate (NaHCO3) or carbon dioxide 

2 (CO2) is added to aid in keeping uranium in its dissolved state. Native ground water would be 

3 fortified with sodium bicarbonate at the CPP and then pumped to the module buildings where 

4 the oxidant and, potentially, CO2 would be added at the injection manifolds located inside the 

5 module buildings (see Figure 2.7).

6

7 The Applicant proposes the 

8 carbonate/bicarbonate lixiviant because of 

9 its compatibility with minerals within the 

10 ore zone. In addition, 

11 carbonate/bicarbonate lixiviants are 

12 generally considered more amenable to 

13 aquifer restoration than other acidic 

14 lixiviants (NRC, 2009). Preliminary leach 

15 testing performed by the Applicant in 2010 

16 demonstrated that this type of lixiviant 

17 successfully mobilized uranium into 

18 solution. Comparison of the Applicant’s 

19 expected concentration ranges of 

20 chemical constituents in the pregnant 

21 lixiviant with the typical lixiviant chemistry 

22 presented in Table 2.4-1 of the GEIS 

23 shows consistency between the Ross Project and the GEIS, except for higher concentrations of 

24 uranium and vanadium that could be present in the pregnant lixiviant at the Ross Project 

25 (Strata, 2011b; NRC, 2009).

26

27 As described in Section 2.4.3 of the GEIS, the recovery wells extract slightly more water than is 

28 injected into the ore-containing aquifer, which creates a “cone of depression” within the 

29 respective wellfield and, thus, maintains an inward flow of ground water. This inflow prevents 

30 migration of lixiviant toward the perimeter monitoring wells. The excess water, referred to as 

31 “production bleed,” is a radioactive byproduct material that must be properly managed and 

32 disposed (NRC, 2009). For the Ross Project, the Applicant proposes a production-bleed range 

33 from 0.5 percent to 2 percent, and averaging 1.25 percent of the injection volume (Strata, 

34 2011b). At the maximum flow rate, approximately 360 L/min [94 gal/min] of production bleed 

35 would be generated. 

36

37 The Applicant proposes to use actual wellfield data and reservoir-engineering software to 

38 predict a sufficient bleed rate to minimize water consumption while the potential for hydraulic 

39 anomalies outside of the uranium-recovery area is minimized (Strata, 2011b). The wellfield 

40 flows would be balanced to produce appropriate bleed based upon the module-injection and 

41 recovery feeder-line meters. The individual well-flow targets would be determined on a per42 pattern basis to ensure that local wellfields are balanced on at least a weekly basis. 

The Applicant proposes a maximum injection pressure of 970 kPa [140 lb2 43 /in] measured at the 

44 injection manifold. This pressure is less than the formation-fracture pressure, which is 

approximately 2,240 kPa [325 lb2 45 /in] at the Ross Project and less than the pressure rating for 

46 operation of the pipes and other equipment (Strata, 2011b). Although injection pressures are 

47 initially expected to be relatively low, pressure requirements within a specific wellfield generally 

48 tend to increase with time. The Applicant suggests that, in order to maintain flow rates and 

What are the basic steps of uranium mobilization?

■ Ground-Water Injection

Uranium mobilization is accomplished by the 

injection of a non-uranium-bearing (“barren”) 

solution, or “lixiviant,” through “injection” wells into 

the uranium-bearing ore zone. The lixiviant moves 

through pores in the ore-zone aquifer, dissolving 

uranium and other metals.

■ Ground-Water Extraction

Recovery, or “production,” wells extract the now 

“pregnant” lixiviant, which contains uranium and 

other dissolved metals, and the solution is then 

pumped to a central processing plant (CPP) for 

further uranium recovery and purification.
DRAFT In Situ Uranium Recovery and Alternatives

2-28

1 wellfield balance, some wells would require flexibility in their allowable injection pressure. To 

2 specifically avoid the injection-restriction problems that plagued the Nubeth operation, the 

3 Applicant has proposed several improvements to well design, well development, and filtration 

4 (Strata, 2011a; Strata, 2011b). 

5

6 Flows and pressures for the injection and recovery pipeline network would be monitored 

7 continuously at the module building, valve manhole, and CPP; the pressures would also be 

8 displayed in the CPP’s control room (Strata, 2011b). Changes in flow or pressure that are 

9 outside of normal operating ranges would result in the activation of visual and audible alarms in 

10 the CPP, and eventually automatic sequential shutdown of pumps and control valves, if the 

11 condition is not corrected promptly.

12

13 In addition, the leak-detection sensors that would be located in the module-building sumps and 

14 the valve manholes would trigger audible and visual alarms at that location and in the CPP if 

15 fluid is detected (Strata, 2011b). The Applicant could also utilize dual leak detection in these 

16 areas, which would consist of two sensors at high and low levels within a module building. If 

17 fluid is detected by the low-level sensor, an audible and visual alarm would be triggered at that 

18 location and in the CPP. If fluid is detected by the high-level sensor, automatic pump shutdown 

19 would occur to prevent the fluid from overflowing the containment system and contaminating the 

20 surrounding environment.

21

22 Pipe and fitting leaks at the wellheads would be detected by sensors located in the wellhead 

23 sumps. In addition, a system would be instituted in the facility’s operating plan for personnel to 

24 inspect the interior of each well module on a weekly basis. Minor leaks or other problems would 

25 be detected in this manner and then promptly repaired to reduce the likelihood of major 

26 releases.

27

28 As noted in SEIS Section 2.1.1, NRC regulations at 10 CFR Part 40, Appendix A, as well as the 

29 individual NRC license that would be issued to the Applicant, would require licensees to have an 

30 operational monitoring-well system to detect excursions. NRC guidance defines an excursion 

31 as occurring when two or more excursion indicators or parameters are present in a monitoring 

32 well or if one excursion parameter exceeds the respective UCLs by 20 percent (NRC, 2009). 

33 GEIS Section 2.4.1.4 described how ISR operations can potentially affect the ground-water 

34 quality near a site, when, during an excursion, lixiviant escapes the production zone, where 

35 uranium recovery is underway, and is not recovered by the intended recovery wells (NRC, 

36 2009). This would result in either a vertical or horizontal excursion. Excursions can be caused 

37 by an improper water balance between injection and recovery wells, undetected high38 permeability strata or geological faults, improperly plugged and abandoned exploration 

39 drillholes, discontinuity within the confining layers, poor well integrity, or unintended fracturing in 

40 the well zone or surrounding units (NRC, 2009). The monitoring of water levels that would be 

41 performed would serve to avert a potential excursion. Water-quality indicators in the ground 

42 water from monitoring wells that would be established after wellfield installation (i.e., post43 licensing, pre-operational baseline concentrations defined as excursion indicators) would also 

44 be used to detect whether an excursion has occurred. 
DRAFT In Situ Uranium Recovery and Alternatives

2-29

1 The NRC would require in

2 its license that the 

3 Applicant conduct 

4 sampling of its monitoring 

5 wells twice each month 

6 and to analyze those 

7 samples for the excursion

8 indicators (i.e., select 

9 baseline water-quality 

10 constituent 

11 concentrations) specified 

12 in its license, so it can be

13 determined whether an 

14 excursion has occurred. 

15 The Applicant has 

16 proposed such an 

17 operational ground-water 

18 monitoring program 

19 (Strata, 2011b). Water 

20 levels would be routinely 

21 measured during the 

22 sampling of the perimeter, 

23 overlying, and underlying 

24 monitoring wells in order 

25 to provide an early 

26 warning for impending 

27 wellfield problems. An 

28 increasing water level in a 

29 perimeter monitoring well 

30 has been shown to be an 

31 indication of a local 

32 flow imbalance within the 

33 wellfield, which could 

34 result in an excursion

35 (Strata, 2011b). An 

36 increasing water level in 

37 an overlying or underlying 

38 monitoring well could be 

39 caused by the migration of 

40 fluid from the ore zone or 

41 by an injection well-casing 

42 failure. As stated above, 

43 samples would also be 

44 collected from the 

45 appropriate monitoring

46 wells once every two 

47 weeks and would be 

48 analyzed for the license49 established excursion 

What are excursion indicators and upper control limits?

Prior to the commencement of injection of lixiviant into a wellfield and actual 

uranium recovery, an Applicant must propose excursion indicators (which 

are water-quality parameter concentrations, such as chloride, that are 

measured to describe the quality of the ground water) as well as upper 

control limits (UCLs) per 10 CFR Part 40, Appendix A, and as per the 

license the NRC would issue (10 CFR Part 40). These indicator chemical 

constituents, or “excursion indicators,” would be based upon post-licensing, 

pre-operational baseline ground-water-quality parameters (i.e., chemical 

constituents occurring in the ground water) and lixiviant chemistry. 

Only after a wellfield and its monitoring-well ring are installed would several 

ground-water samples would be obtained and analyzed by the Applicant. 

The results of these analyses provide post-licensing, but pre-operational, 

baseline values for the respective ground-water-quality parameters that 

would be used to indicate contemporary ground-water quality. If, during 

ISR operations, two indicator constituents’ are exceeded, or if one is 

exceeded by 20 percent, (with respect to the corresponding UCLs), then an 

excursion of lixiviant would be defined as occurring. 

UCLs are set on a wellfield-by-wellfield basis and are stated in constituent 

concentrations for selected excursion indicators so as to provide early 

warning if uranium-bearing solutions (lixiviant) are moving away from a 

particular wellfield. The UCLs are subject to the NRC’s staff review and 

approval and their establishment would be required in the NRC license. As 

described by the NRC (2003a), the best excursion indicators are easily 

measurable parameters that are found in higher concentrations during 

uranium recovery than in the natural ground water. 

At most in situ uranium-recovery operations, for example, chloride is often 

selected because it does not interact strongly with the minerals in the ore 

zone; it is easily measured; and chloride concentrations are significantly 

increased during ISR operations. Conductivity, which is correlated to total 

dissolved solids (TDS), is also considered a good excursion indicator 

because of the high concentrations of dissolved constituents in the lixiviant 

as compared to the surrounding aquifers (Staub et al., 1986, and Deutsch 

et al., 1985, as cited in NRC, 2009b). Total alkalinity (carbonate plus 

bicarbonate plus hydroxide) is used as an indicator in wellfields where 

sodium bicarbonate or carbon dioxide is used in the lixiviant.

At least three excursion indicators are selected to be monitored in each 

wellfield, and the UCLs are determined using statistical analyses of the 

post-licensing, pre-operational baseline water quality in the respective 

wellfield. The NRC staff has identified several statistical methods that can 

be used to establish UCLs. For example, in areas with good water quality 

(TDS less than 500 mg/L), the UCL could be set at a value of 5 standard 

deviations above the mean of the measured concentrations. Conversely, if 

the chemistry or a particular excursion indicator is very consistent, a 

specific concentration could be specified as the UCL. If post-licensing, preoperational baseline data indicate that the ground water is homogeneous 

across the wellfield, the same UCLs could be used for all monitoring wells. 

Alternatively, if the water chemistry in the wellfield is highly variable, unique

UCLs could be set for individual wells. 

An excursion is defined to occur when two or more excursion indicators in a 

monitoring well exceed their UCLs (NRC, 2003a). Alternate excursion 

detection procedures (e.g., one excursion indicator exceeded in a 

monitoring well by a specified percentage) could also be used, if approved 

by the NRC.
DRAFT In Situ Uranium Recovery and Alternatives

2-30

1 parameters. In addition, the Applicant expects that dedicated pressure transducers and/or in 

2 situ water-quality instruments could be used in the perimeter monitoring wells to provide the 

3 earliest detection of potential excursions or hydraulic anomalies. The Applicant anticipates that 

4 this monitoring effort would allow corrective action to be immediately taken to balance locally the 

5 injection and recovery flows or to shut down individual injection well(s) or the entire wellfield, as 

6 necessary (Strata, 2011b).

7

8 Per conditions that the NRC would include in the Ross Project’s license, the Applicant would be 

9 required to notify the NRC within 24 hours if an excursion were confirmed in the Project’s 

10 ground-water monitoring wells. If a vertical excursion occurs, then the Applicant’s injection of 

11 lixiviant would cease and, for any excursion, corrective action would be initiated (the GEIS 

12 documented that vertical excursions tend to be more difficult to recover than horizontal 

13 excursions) (NRC, 2009). The NRC would require in the Applicant’s license that verification and 

14 progress ground-water samples are collected by the Applicant weekly until the excursion 

15 indicators are at or below their respective UCLs (i.e., the excursion is “recovered”) as indicated 

16 by three consecutive weekly samples. 

17

18 The Applicant would also be required to provide a report to NRC within 60 days, including a 

19 confirmation of an excursion, a description of the excursion, a discussion of the corrective 

20 actions taken, and the results of those corrective actions. If an excursion cannot be recovered 

21 within 60 days of confirmation (measured by a concentration of more than 20 percent of any 

22 excursion indicator), the Applicant would be required either to terminate lixiviant injection within 

23 the wellfield until aquifer cleanup is complete (for horizontal excursions) or to increase the 

24 surety for the ISR project by an amount sufficient to cover the full third-party cost of correcting 

25 and remediating the excursion. As the GEIS described in Section 2.11.4, licensees typically 

26 retrieve horizontal excursions back into the production zone by repairing and reconditioning 

27 wells and adjusting pumping rates in the wellfield. 

28

29 Uranium and Vanadium Processing

30

31 Uranium and vanadium in pregnant lixiviant would be extracted from solution by IX resin, 

32 stripped from the loaded IX resin (“eluted”), precipitated into a slurry, thickened, de-watered, 

33 dried, and packaged as yellowcake (Strata, 2011b). Prior to introduction to the IX columns, 

34 pregnant lixiviant could be passed through a de-sanding filtration system (Strata, 2011b). 

35 Carbon dioxide could also be added to the pregnant lixiviant to optimize the IX resin-loading 

36 capacity. The filtered, pregnant lixiviant would then be passed through two-stage, pressurized, 

37 down-flow IX columns, where the uranium and the vanadium dissolved in the lixiviant would be 

38 selectively adsorbed onto the IX resin beads. In exchange of uranium and vanadium, the resin 

39 releases chloride, bicarbonate, or sulfate ions into the lixiviant. The barren lixiviant exiting the 

40 second IX column would be monitored and would normally contain less than 2 mg/kg (“parts per 

41 million” or “ppm”) of uranium. When the resin beads in the IX column become saturated with 

42 uranium and vanadium, the columns would be taken offline for resin elution.

43 Prior to elution (“elution” is the process whereby the resin beads are “washed” with water to 

44 remove uranium and vanadium), the loaded uranium-bearing resin would be transferred to 

45 vibrating screens to wash away sand, silt, broken resin, scale, and other process contaminants. 

46 The solid material recovered during this step would be collected, stored, and disposed of as a 

47 byproduct waste. The elution process would then consist of four stages. The first three 

48 sequential stages are where a single batch of resin is contacted with a volume of eluant (water 
DRAFT In Situ Uranium Recovery and Alternatives

2-31

1 containing approximately 10 percent sodium chloride and 2 percent sodium carbonate) three 

2 times the volume of the batch of loaded resin. The fourth stage is a final rinse where the batch 

3 of resin is contacted with four bed volumes, or pore volumes, of fresh water (i.e., four bed 

4 volumes is equal to four times the amount of pore space [i.e., empty space] in the resin) (Strata, 

5 2011b). In addition to processing resin from the Ross Project wellfields, the elution circuit 

6 would have the capacity to process loaded resin from other uranium-recovery operations owned 

7 either by the Applicant or another company as well as from water-treatment facilities that use IX 

8 resin to filter or condition water (Strata, 2011b).

9

10 The precipitation circuit produces a slurry of uranium solids from the eluant. The Applicant

11 proposes a design consisting of multiple precipitation tanks plumbed in series, with mechanical 

12 agitation. The sequential addition of chemicals to bring about precipitation would be as follows: 

13 1) sulfuric acid, 2) sodium hydroxide (caustic soda), 3) hydrogen peroxide, and 4) sodium 

14 hydroxide. The slurry containing the uranium precipitate would then be pumped to a yellowcake 

15 thickener, which separates the solids particles from the liquid. The “underflow” from this 

16 thickener (i.e., the still-wet separated solids) would then undergo a second stage of dissolution 

17 and precipitation to remove any impurities entrained in the first precipitate (the underflow). The 

18 “overflow” (i.e., the liquid with few solid particles remaining after precipitation) from both 

19 thickener stages would then go to the vanadium-recovery circuit.

20

21 After precipitation, the yellowcake slurry would be washed in a filter press to remove excess 

22 chloride and other soluble contaminants. After multiple washings, the filter cake would be 

23 transferred to a radiologically controlled area for drying and packaging (Strata, 2011b). Drying 

24 would be accomplished in completely enclosed low-temperature vacuum dryers. The GEIS 

25 describes the type of dryer proposed by the Applicant as the standard for newer ISR facilities 

26 (NRC, 2009). The off-gases generated during the drying cycle would be filtered and scrubbed 

27 to remove entrained particulates. The GEIS noted that the drying, filtration, and scrubber 

28 process proposed by the Applicant is designed to capture virtually all escaping particles (NRC, 

29 2009).

30

31 The dryers would be batch type, and drying would typically take 16 hours per batch. Batch 

32 dryers create the potential for the escape of yellowcake during loading and unloading of the 

33 dryer. The Applicant proposes to reduce this potential by the design of the equipment. A water34 sealed vacuum pump would provide ventilation during loading of the yellowcake slurry into the 

35 dryer and transferring the dried product into 208-L [55-gal] drums by facility personnel (Strata, 

36 2011b). Transfer equipment would be located directly below the dryer and would include a 

37 discharge chute, rotary airlock valve, ventilated drum hood, and a drum conveyor. A drum 

38 would be placed beneath the dryer discharge chute; the ventilation hood would be secured over 

39 the drum opening to prevent escape of yellowcake into the surrounding environment. After a 

40 drum is in place and securely covered, the rotary airlock valve would be activated to start the 

41 loading process. A viewport in the hood would allow personnel to determine when the drum is 

42 full. The loaded drum would be weighed and labeled, and then moved to the side to cool and 

43 off-gas before it is sealed and stored for offsite shipment. 

44

45 The uranium-depleted solutions from the uranium thickeners would be pumped to a vanadium 

46 precipitation tank (Strata, 2011b). Steam, facility air, ammonia, and ammonium sulfate would 

47 be added to cause precipitation of crystals containing vanadium. The precipitate slurry would 

48 be pumped to a horizontal belt filter, where the solution is removed from the crystals. The filter 
DRAFT In Situ Uranium Recovery and Alternatives

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1 cake would be washed and transferred to a batch vacuum rotary dryer similar to the dryer that 

2 would be used to dry uranium yellowcake. Off-gas from the precipitation tanks and dryer would 

3 be filtered to remove particulates and directed to a wet scrubber to capture ammonia for reuse. 

4 The dried product would then be packaged for offsite shipment. The Applicant estimates that 

5 0.1 – 2 kg [0.2 – 4.4 lb] of V2O5 would be produced for every 1 kg [2.2 lb] of U3O8.

6

7 The waste water would be treated by reverse osmosis (RO) (Strata, 2011b). The water quality 

8 of permeate that is anticipated by the Applicant is provided in Table 2.2. Most of the permeate 

9 from the RO system would be recycled back to the wellfield as lixiviant. The lined surface 

10 impoundments within the facility would be used to store and manage excess permeate and 

11 brine. Permeate and brine would be managed as radioactive byproduct materials. Brine 

12 would be disposed in the deep-injection wells.

13

Table 2.2

Permeate Water Quality

Parameter Unit

Typical

Value

Minimum

Value

Maximum

Value

EC μS/cm 300 180 400

TDS mg/L 200 100 250

pH s.u. 8 6 6.5

Alkalinity as

CaCO3

mg/L 100 50 200

Sulfate mg/L 15 10 20

Bicarbonate mg/L 150 50 200

Chloride mg/L 15 5 25

Calcium mg/L 0 0 1

Sodium mg/L 50 20 100

Manganese mg/L 0 0 0.1

Selenium mg/L 0 0 0.1

Arsenic mg/L 0 0 0.1

Uranium mg/L 0 0 0.1

Radium pCi/L 30 5 100

14 Source: Table 4.2-2 in Strata, 2011b.

15 2.1.1.3 Ross Project Aquifer Restoration

16

17 After uranium recovery has ended, each wellfield that is to undergo aquifer restoration would 

18 contain ground-water constituents that would have been mobilized by the lixiviant. The purpose 

19 of aquifer restoration is to restore the respective aquifer to its baseline conditions, as defined by 

20 post-licensing, pre-operational constituent concentrations (see Section 2.1.1.2), so as to ensure 

21 public health and safety. The Applicant would be required to provide a financial-surety 

22 instrument that would cover planned and delayed aquifer-restoration costs in compliance with 

23 10 CFR Part 40, Appendix A, Criterion 9 to cover the ISR facility’s decontamination and 

24 decommissioning. NRC would review the adequacy of this financial-surety annually (see SEIS 

25 Section 2.1.1.7) (10 CFR Part 40).
DRAFT In Situ Uranium Recovery and Alternatives

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1 Under the Federal UIC program, the exempted production aquifer would no longer be used as a 

2 USDW under the SDWA (40 CFR Part 145). In accordance with the requirements for a Class I3 V well under 40 CFR Part 146.4, the exempted aquifer does not currently serve as a source of 

4 drinking water and cannot now and would not in the future serve as a source of drinking water 

5 (40 CFR Part 146). Hence, ground water in exempted aquifers cannot be considered as a 

6 source of drinking water after restoration.

7

8 The aquifer-restoration activities proposed for the Ross Project are the same as those methods

9 described in Section 2.5 of the GEIS: 1) ground-water transfer, 2) ground-water sweep, 3) RO 

10 with permeate injection, 4) ground-water recirculation, and 5) stabilization monitoring (Strata, 

11 2011a; NRC, 2009). The Applicant proposes that concurrent ISR operations and aquifer 

12 restoration would occur when several of the first well modules have been depleted and are 

13 ready for restoration activities (Strata, 2011b). As aquifer restoration occurs in depleted well 

14 modules, ISR operations would be ongoing in subsequent well modules. 

15

16 The Applicant has proposed a ground-water restoration schedule that is benchmarked to 

17 production schedules and waste-water disposal capacity, but it estimates that aquifer restoration 

18 for each wellfield would take approximately eight months (Strata, 2011b). The Applicant’s 

19 proposed restoration methodology would include ground-water sweep, permeate injection, and 

20 ground-water recirculation.

21

22 During ground-water sweep, water is pumped from injection and recovery wells to the facility 

23 without reinjection, as the GEIS described in Section 2.5.2. In response to this pumping, water 

24 from outside the wellfield flows into the ore zone, flushing contaminants from areas that have 

25 been affected by the horizontally spreading lixiviant in the respective aquifer during uranium 

26 recovery (NRC, 2009). Ground water produced during the sweep phase would contain uranium 

27 and other contaminants mobilized during uranium recovery as well as residual lixiviant. The 

28 initial concentrations of these constituents would be similar to those during uranium recovery, 

29 but the concentrations would decline gradually with time. The water removed from the aquifer 

30 during the sweep first would be passed through the IX system to recover the uranium and then 

31 be disposed of as excess permeate. The pumping rates used would depend on the hydrologic 

32 conditions at the Ross Project, and the duration of the aquifer sweep and the volume of water 

33 removed would depend on the volume of the aquifer affected by the ISR process. 

34 Aquifer volume typically is described in terms of “pore volumes,” a term used by the ISR 

35 industry to represent the volume of water that fills the void space in a given volume of rock or 

36 sediment. The Applicant’s aquifer-restoration plan calls for removing up to 0.5 pore volumes of 

37 water during ground-water sweep (Strata, 2011b). Additional pumping would occur in select 

38 areas that would be identified during facility operation. The pumping rate is estimated at 284 

39 L/min [75 gal/min] from well modules in the ground-water sweep stage. The Applicant proposes 

40 to use ground-water sweep selectively (for example, around the perimeter of the wellfield) rather 

41 than throughout the entire well module to minimize the consumptive use of ground water 

42 (Strata, 2011a). 

43

44 The Applicant proposes to use ground-water treatment and permeate injection would be used 

45 after the ground-water sweep process, as described in Section 2.5.3 of the GEIS (Strata, 

46 2011b). This phase would return total dissolved solids (TDS) (a water-quality parameter), trace47 metal concentrations, and aquifer pH to the pre-operational baseline values that would have 
DRAFT In Situ Uranium Recovery and Alternatives

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1 been determined during the Applicant’s post-licensing, pre-operational sampling and analysis 

2 program; these concentrations would be required by the NRC license (NRC, 2009). Ground 

3 water recovered from a depleted portion of the ore zone would be treated with sulfuric acid or 

4 other chemicals to prevent scaling on the RO circuit (Addendum 6.1-A in Strata, 2011b). Low 

5 concentrations of uranium in the ground water would be removed by passing the water through 

6 the IX circuit, as during operations. Following the IX circuit, other chemical constituents are 

7 removed by passing the ground water through the two-phase RO system consisting of 

8 pressurized, semi-permeable membranes. The RO process yields two fluids: permeate 

9 (approximately 85 percent), which would be re-injected into the aquifer, and brine 

10 (approximately 15 percent), which would be managed as liquid waste. 

11

12 The pumping and injection rates during this process would be similar to those during the sweep 

13 phase, but depending upon site hydrology, many pore volumes (often more than 10) could be 

14 circulated to achieve aquifer restoration goals (NRC, 2009). For the Ross Project, the Applicant

15 estimates that aquifer restoration would average 3,880 L/min [1,025 gal/min] from well modules 

16 in the RO and permeate-injection process of aquifer restoration (Strata, 2011b). During aquifer 

17 restoration (except during ground-water sweep), all permeate would be used as lixiviant or 

18 injected into the aquifer for restoration. 

19

20 The ground-water recirculation process would begin after completion of the permeate-injection 

21 process. In this phase, ground water from the production zone would be pumped from recovery 

22 wells and re-circulated into injection wells in the same well module. This process homogenizes 

23 the ground water within the aquifer to minimize the risk of “hot-spots,” areas of the aquifer with 

24 unusually high concentrations of dissolved metal concentrations. The Applicant proposes that 

25 the only water treatments that would occur during recirculation are filtration and removal of 

26 uranium and vanadium (Strata, 2011a).

27

28 The purpose of stabilization during aquifer restoration is to establish a chemical environment 

29 that would reduce the solubility of dissolved constituents such as uranium, arsenic, and 

30 selenium, as described in GEIS Section 2.5.4. An important component of aquifer stabilization 

31 during the aquifer-restoration phase is to convert metals to their insoluble forms (NRC, 2009). If 

32 the oxidized (i.e., the more soluble) state is allowed to persist after uranium recovery is 

33 complete, metals and other constituents such as arsenic, selenium, molybdenum, uranium, and 

34 vanadium could continue to leach and remain at elevated levels. To stabilize these 

35 constituents’ concentrations, the pre-operational oxidation state in the ore zone must be 

36 reestablished as much as is possible. This stabilization often requires adding an oxygen 

37 scavenger or a reducing agent, such as hydrogen sulfide (H2S) or a biodegradable organic 

38 compound such as ethanol, into the production zone during the later stages of recirculation 

39 (NRC, 2009). 

40

41 The need for aquifer stabilization would be determined on a case-by-case basis and would 

42 depend upon how effectively the sweep and recirculation processes restore the affected aquifer 

43 to the license-required standards. Following aquifer restoration, the Applicant would monitor the 

44 ground water by quarterly sampling to demonstrate that the approved standard for each 

45 constituent has been met and that any adjacent nonexempt aquifers are unaffected. The 

46 Applicant would reinitiate the entire aquifer restoration phase if stabilization monitoring 

47 determines it is necessary. Both WDEQ and the NRC must review and approve all monitoring 

48 results before aquifer restoration would be considered to be complete.
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1 All injection, recovery, and monitoring wells and drillholes would be plugged and abandoned in 

2 place according to applicable regulations after ground-water restoration is approved by the NRC 

3 and WDEQ (WDEQ/LQD, 2005). To comply with these regulations, the Applicant proposes

4 standard operating procedures (SOPs) of well abandonment that includes plugging all wells with 

5 cement containing 2 percent bentonite clay (Strata, 2011b). 

6

7 2.1.1.4 Ross Project Decommissioning

8

9 Prior to the Ross Project’s facility decontamination, dismantling, and decommissioning; the 

10 wellfields’ aquifer restoration; and the Project site’s reclamation and restoration; appropriate 

11 cleanup criteria for surfaces would need to be established in concert with NRC requirements, 

12 and a Ross Project-specific decommissioning plan (DP) would need to be accepted by the NRC 

13 (NRC, 2003b). The Applicant has committed to satisfying these NRC requirements for 

14 decontamination and decommissioning (Strata, 2011b). 

15

16 To begin the Ross Project’s decommissioning phase, the Applicant would conduct a series of 

17 radiation surveys to identify those areas at the Ross Project that would need decontamination to 

18 meet applicable cleanup criteria or those that cannot economically meet the criteria (Strata, 

19 2011b). These surveys would include building, structural, and equipment surfaces as well as 

20 potentially contaminated environmental media such as soil and water (NRC, 1999; NRC, 

21 2003a). The onsite excavated pits, or “mud pits,” used for the disposal of drilling fluids and 

22 muds (or “cuttings”) during the installation of wells, would be included in the survey to ensure no 

23 long-term radiological impacts (Strata, 2011a). In addition, records of radiation surveys and the 

24 entire cycle of decontamination, dismantling, decommissioning, and disposal activities would be 

25 maintained in accordance with the Applicant’s license.

26

27 Based upon the results of the radiation surveys, decontamination and dismantling of buildings, 

28 structures, and equipment would be conducted in accordance with the DP. Contaminated 

29 surfaces, including processing and water-treatment equipment such as tanks, filters, IX 

30 columns, pipes, and pumps, would be decontaminated (Strata, 2011b). High-pressure washing 

31 would be used to remove loose contamination from the surfaces. If required, secondary 

32 decontamination would consist of washing with dilute acid or equivalent compatible solution 

33 (Strata, 2011b). All successfully decontaminated buildings and equipment could be released for 

34 unrestricted use (NRC, 2003b).

35 The buildings, structures, and equipment that are not or no longer contaminated would be 

36 moved to a new location within the Ross Project for further use or storage, removed to another 

37 facility for either reuse or salvage, or taken to a properly permitted, permanent solid-waste 

38 disposal facility. Concrete flooring, foundations, and foundation materials, if uncontaminated, 

39 would be broken up and disposed of at an appropriately permitted solid-waste facility. All 

40 radioactively contaminated buildings and structural materials that cannot be successfully 

41 decontaminated would be dismantled and then disposed of at a properly licensed radioactive 

42 waste disposal facility (i.e., a facility licensed by the NRC or an Agreement State). 

43 Contaminated soils would also be disposed of at the same or similar licensed facility. A final44 status radiation survey would then be performed to ensure that any residual contamination on 

45 the surfaces is below the cleanup criteria. All disturbed lands would be reclaimed (NRC, 1999). 

46 Section 2.6 of the GEIS describes the general process for decontamination, dismantling, and 

47 decommissioning of an ISR facility and the restoration and reclamation of the land itself (NRC, 

48 2009). 
DRAFT In Situ Uranium Recovery and Alternatives

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1 During decommissioning of the facility, all UIC Class III injection and recovery wells, monitoring 

2 wells, and the UIC Class I injection wells would be abandoned according to the DP. The total 

3 number of wells would number between 750 and 1,000 based upon the Applicant’s estimate of 

4 40 recovery wells per each of 15 – 20 wellfield modules plus monitoring wells (Strata, 2012a). 

5 Decontamination, decommissioning, and restoration of a wellfield would begin approximately 

6 five years after its construction (refer to Figure 2.6) (Strata, 2011a). However, at the Ross 

7 Project, complete decontamination, dismantling, and decommissioning of the ISR facility itself, 

8 and restoration and reclamation of the Ross Project area, could occur years after the wellfields 

9 begin to be decommissioned and the aquifer begins to be restored, in order to accommodate 

10 the Applicant’s continuing recovery of uranium and production of yellowcake from its future 

11 satellite projects and/or from other uranium-recovery or waste-water-treatment operations 

12 (Strata, 2011a).

13

14 During the decommissioning phase, the Applicant proposes that all primary, secondary, and 

15 tertiary roads and other temporary access routes to and within the Ross Project would be 

16 removed and the land reclaimed, unless a request by the respective landowners or lessees to 

17 not do so is received by the Applicant. In this case, then, the landowners or lessees would 

18 assume responsibility for the long-term maintenance and ultimate reclamation of the roads and 

19 routes, after the NRC license has been withdrawn (Strata, 2011b).

20

21 All contaminated soil or gravel that is determined to be a byproduct radioactive waste would be 

22 disposed at a radioactive waste disposal facility licensed by the NRC or an Agreement State, as 

23 necessary, while petroleum-contaminated soil would be disposed at a WDEQ-permitted facility. 

24 Removal of roads would be accomplished by the Applicant removing excess road surfacing 

25 material, and then ripping the road and the underlying shallow subsoil to loosen the base. 

26 Culverts would be removed and preconstruction drainages would be re-established. The vicinity 

27 would be graded to a contour consistent with the surrounding landscape. Finally, topsoil would 

28 be applied in a uniform manner and the area seeded to achieve WDEQ/LQD reclamation 

29 standards. 

30

31 The Class I deep-disposal wells would be plugged and abandoned in accordance with the 

32 requirements of the Applicant’s UIC Class I Permit (Strata, 2011b). All wastes and the 

33 equipment associated with the surface impoundments, such as accumulated sludge, 

34 impoundment liners, and leak-detection pipes and lines, would be surveyed for radioactive 

35 contamination and then disposed of appropriately or released for unrestricted use (Strata, 

36 2011b). The soil beneath the surface impoundments would be analyzed for radioactive 

37 contamination, and any areas that exceed the cleanup criteria for unrestricted release would be 

38 excavated and disposed of at a licensed radioactive waste disposal facility.

39

40 The natural flow of shallow ground water beneath the facility and in the immediate vicinity 

41 outside of the CBW would also be re-established during decommissioning (Strata, 2011b). Flow 

42 through the CBW would be accomplished by the Applicant’s creating a series of breaches, also 

43 known as finger drains, along the up-gradient and down-gradient reaches of the CBW. Each 

44 finger drain would 

45

46 consist of a 0.5 m [1.5 ft] wide by 7.6 m [25 ft] long trench that is cut through the CBW at a right 

47 angle and to a depth that is 0.6 m [2 ft] below the lowest historical ground-water level. Gravel 

48 would be placed in the trench from the bottom to a point 0.6 m [2 ft] above the highest recorded 

49 ground-water level such that a highly permeable flow path is created through the CBW. The 
DRAFT In Situ Uranium Recovery and Alternatives

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1 remaining trench would be 

2 backfilled with native topsoil and 

3 seeded. Selected monitoring 

4 wells that would have been used 

5 by the Applicant to characterize 

6 the shallow aquifer in the area, 

7 before its installation of the CBW, 

8 would be retained. Water levels 

9 would be monitored following 

10 CBW reclamation to verify that 

11 the natural flow of shallow ground 

12 water through the CBW and 

13 beneath the facility has been 

14 restored.

15

16 The Applicant proposes to re17 contour, as necessary, the 

18 disturbed areas within the Ross 

19 Project area to blend in with the 

20 natural terrain and to be 

21 consistent with the 

22 preconstruction topography 

23 (Strata, 2011b). Revegetation 

24 would be accomplished in 

25 accordance with the WDEQ/LQD 

26 Permit to Mine requirements and 

27 would be required by the NRC 

28 license. Topsoil that was 

29 salvaged prior

30 to construction activities and 

31 stored in a stockpile would be 

32 used for reclamation to the 

33 extent possible (Strata, 2011b); 

34 the topsoil would be spread 

35 over the area to be reclaimed 

36 and would be seeded with a native seed mix. During ISR facility operation the topsoil stockpiles 

37 and as much as is practical of the disturbed wellfield, would be seeded to establish vegetative 

38 cover to minimize wind and water erosion. At the completion of decommissioning, the Applicant

39 commits to reclaiming the entire area to equal or better conditions than existed prior to ISR 

40 (Strata, 2011b, Addendum 6.1-A). Reclaimed land would be capable of supporting livestock 

41 grazing, dry-land farming, and wildlife habitat. The respective landowners and WDEQ would be 

42 consulted as the Applicant selects the seed mix. Seeding would be conducted by drill or 

43 broadcast methods depending upon the type of seed being used. Mulch could also be used to 

44 cover the seed (Strata, 2011b).

45

46 2.1.1.5 ISR Effluents and Waste Management

47

48 Section 2.7 of the GEIS describes the airborne effluents as well as the liquid and solid wastes 

49 that are typically generated at ISR facilities and corresponding waste-management practices 

What types of wastes would be generated at the proposed 

Ross Project?

Liquid Wastes

Liquid Byproduct Waste is all liquid-phase wastes generated 

by the proposed Ross Project, except for sanitary waste water 

and well development and testing waste water. This waste is 

contaminated with byproduct material.

Liquid Hazardous Waste is regulated under the Resource 

Conservation and Recovery Act or is a State-defined 

hazardous waste that is a non-byproduct waste. This waste 

includes universal hazardous wastes and used oil. 

Sanitary Waste Water is ordinary sanitary septic-system 

waste water; this waste water is non-hazardous, nonbyproduct waste water. 

Well Development and Testing Waste Water is waste water 

generated during well development and during pumping tests; 

this waste water is non-hazardous, non-byproduct waste 

water. Such waste water does not require treatment before 

disposal.

Solid Wastes

Solid Byproduct Waste is all solid-phase wastes generated 

by the Ross Project that exceed NRC limits at 10 CFR Part 20 

for unrestricted release. This waste is contaminated with 

byproduct material.

Hazardous Waste is regulated under the Resource 

Conservation and Recovery Act or is a State-defined 

hazardous waste that is non-byproduct waste. This waste 

includes universal hazardous wastes. 

Nonhazardous Solid Waste is domestic, office, and municipal 

waste (i.e., trash), construction and demolition debris, septic 

solids, and materials such as equipment and soils that have 

been determined to meet NRC criteria in 10 CFR Part 20 for 

unrestricted (i.e., unregulated) release.
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1 (NRC, 2009). The effluents and wastes expected from the proposed ISR project and the waste2 management practices the Applicant proposes are consistent with the industry standards 

3 reported in the GEIS. The types of liquid and solid wastes, the quantities of these wastes 

4 anticipated by the Applicant, and the Applicant’s proposed management systems are provided 

5 in Strata (2012a). (See also Table 4.9 in SEIS Section 4.14.) Impacts from liquid and solid 

6 waste management are described in SEIS Section 4.14. 

7

8 Airborne Emissions

9

10 There would be both radioactive and non-radioactive airborne particulates and gases emitted 

11 during all phases of the Proposed Action (Strata, 2011b). As discussed below, the design 

12 features proposed by the Applicant to control all airborne effluents are consistent with the 

13 industry standards presented in the GEIS (NRC, 2009). 

14

15 Non-Radioactive Emissions

16

17 Emissions from internal combustion engines would be the primary source of non-radioactive 

18 gaseous effluents (i.e., emissions). Releases would be anticipated from drilling rigs, drilling 

19 support equipment (e.g., backhoes, water trucks, pipe trucks, and cement units), utility trucks 

20 employed for wellfield service, light vehicles used for personal transport through the wellfields, 

21 in addition to vehicles used by ISR facility personnel to and from the Ross Project area (Strata, 

22 2011b). The emissions from these types of vehicles would include carbon monoxide (CO), CO2, 

23 sulfur dioxide (SO2), nitrogen species (NOx), and total hydrocarbon (THC) as well as particles 

24 less than 10 μm in diameter (PM10) (Strata, 2011a). These emissions are consistent with those 

25 from a generic ISR project described in the GEIS (NRC, 2009).

26

27 Smaller sources of airborne non-radioactive gaseous and particulate emissions during operation 

28 would also include fugitive dust from cementing operations; welding fumes; particulates from 

29 grinding steel during construction and during operation; salt and soda ash during process30 chemical delivery; and fumes from chemicals used in the laboratory, in addition to the carbon 

31 dioxide, oxygen, and water vapor that would be vented from the Ross Project. Vanadium 

32 precipitation, drying, and packaging would also present a potential for non-radioactive 

33 particulate emissions. 

34

35 Fugitive dust would also be generated during all phases of the Proposed Action due to the 

36 mechanical disturbance of soil by heavy equipment, from transport vehicles traveling on access 

37 roads, and from wind blowing over disturbed areas and stockpiles. The Applicant has proposed 

38 to mitigate fugitive-dust emissions with its use of speed limits, strategic placement of water39 loading facilities near access roads, suppression of dust with chemicals such as magnesium 

40 chloride, selection of road-surface materials that would minimize dust, and prompt revegetation 

41 of disturbed areas (Strata, 2011a). 

42

43 Radioactive Emissions

44

45 Radon gas would be the primary radioactive gaseous effluent from the Ross Project. Radon is 

46 a radioactive, colorless, and odorless gas that occurs naturally as the decay product of radium, 

47 which is found where there is uranium as radium itself is a radioactive decay product of 

48 uranium. Radon would be found in the lixiviant solution that is extracted from the wellfields and 

49 piped to the CPP for processing. Radon gas could potentially be released in the CPP as a 
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1 result of uranium-recovery fluid spills, filter changes, IX resin-transfer operations, and 

2 maintenance activities. Routine monitoring of radon progeny (i.e., the products of radon’s own 

3 radioactive decay) within the CPP would identify exposure levels and would allow timely 

4 corrective actions to be initiated, if necessary (Strata, 2011b). The sources of radon described 

5 by the Applicant and the design features proposed by the Applicant to limit radon concentrations

6 (e.g., the use of proper ventilation systems and radon detectors) are consistent with the industry 

7 standard described in the GEIS (NRC, 2009).

8

9 All exhaust points in the CPP would be ducted through a common system to a wet scrubber and 

10 discharged to the atmosphere (Strata, 2011b). The Applicant has committed that these 

11 discharges would meet all local, State, and Federal requirements related to air quality as well as 

12 occupational health and safety (Strata, 2012b). A performance-monitoring station would be

13 located at the CPP’s exhaust fan’s point of discharge at the roof. The ambient air within the 

14 facility would be gravity ventilated up through a ridge vent. The CPP and other buildings would 

15 also be passively ventilated by the opening and closing of doors during periods of time when 

16 radon could be released. 

17

18 Radon gas could also be released outside of the CPP from wellheads, other auxiliary buildings 

19 such as well modules, and the surface impoundments (Strata, 2011b). At the wellheads and the 

20 surface impoundments, radon would be released directly to the atmosphere, where it would 

21 rapidly disperse and decrease in concentration. Wellhead enclosures, such as the module 

22 buildings, would be vented to reduce radon buildup that could otherwise expose wellfield

23 personnel to radon during inspection and maintenance activities. The Applicant proposes that, 

24 if vents are not installed on wellhead enclosures, SOPs would be developed for accessing 

25 wellheads to ensure radon exposures are below the regulatory limits of the EPA and the NRC. 

26 Such buildings would have ventilation systems consisting of a roof- or wall-mounted fan as well 

27 as a separate radon ventilation system with an intake located in the building’s sump and an 

28 exhaust point on the building’s roof.

29

30 Potential radioactive particulate emissions would consist primarily of airborne yellowcake in the 

31 uranium drying and packaging process (Strata, 2011b). This potential would be mitigated by 

32 design features to prevent releases into the atmosphere as described earlier in this section of 

33 this SEIS.

34 Liquid Effluents

35

36 The GEIS, Section 2.7.2, describes the liquid effluents generated during all phases of uranium 

37 recovery: construction, operation, aquifer restoration, and decommissioning. During most of 

38 these phases, liquid wastes could contain elevated concentrations of radioactive and chemical 

39 constituents. The composition and quantities of liquid waste from Ross Project processes 

40 related to uranium recovery are similar to those ranges provided in Table 2.7-3 of the GEIS 

41 (NRC, 2009); however, representative water quality parameter(s) for permeate are not included 

42 in the GEIS for comparison. The methods that the Applicant proposes for treatment of liquid 

43 wastes, such as RO as well as its disposal and management practices, are similarly noted as 

44 industry standards in the GEIS (NRC, 2009). 

45

46 The Proposed Action would generate liquid effluents classified as byproduct wastes as well as 

47 other liquid effluents that are not (Strata, 2011b; Strata, 2012a). Liquid wastes would be 

48 categorized as follows:
DRAFT In Situ Uranium Recovery and Alternatives

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1

2 ■ Brine and permeate from the RO treatment of lixiviant bleed and ground water from aquifer 

3 restoration. Most of the permeate would be reused as lixiviant in the wellfields and as 

4 process make-up water.

5 ■ Other liquids such as spent eluate, collected fluids from drains in the processing areas at the 

6 CPP, contaminated reagents, IX resin wash water, filter back wash, facility wash-down 

7 water, decontamination water (e.g., employee showers), and fluids generated from work8 over and enhancement operations on injection and recovery wells.

9 ■ Non-byproduct liquid wastes would include drilling fluids and ground water collected during 

10 construction and development of injection, recovery, and monitoring wells as well as during 

11 environmental sampling and aquifer testing; storm-water runoff; toxic and hazardous wastes 

12 such as petroleum products and spent chemicals; and domestic sewage. 

13

14 The Applicant proposes the use of surface impoundments for the collection and management of 

15 byproduct waste liquids (Strata, 2011a). Production of liquid byproduct wastes would vary over 

16 the three phases of operations and ground-water restoration: 1) operation only; 2) concurrent 

17 operations and aquifer restoration; and 3) aquifer restoration (Strata, 2011b). 

18

19 GEIS Section 2.7.2 described four disposal options for use at ISR facilities: evaporation, land 

20 application, deep-well injection, and surface-water discharge (NRC, 2009). Of these disposal 

21 options, the Applicant proposes to rely on deep-well injection, with supplemental disposal by 

22 evaporation of brine and disposal of excess permeate from the surface impoundments (Strata, 

23 2011b; Strata, 2012a). Land application is not currently proposed as a method for permeate 

24 disposal by the Applicant (Strata, 2012b). The surface impoundments would primarily provide 

25 transient storage of liquids with little evaporation actually occurring during the liquids’ residence 

26 time. 

27

28 Excess permeate could be produced during two relatively brief periods of operations (Strata, 

29 2011b): the first two and one-half years of uranium production without reinjection of permeate 

30 into the aquifer for wellfield restoration and the two months when ground-water sweep is 

31 occurring in the first wellfield modules to undergo aquifer restoration. The Applicant proposes 

32 that excess permeate during the periods of uranium-recovery would be disposed of by deep33 well injection (WWC Engineering, 2013). As noted earlier, the Applicant would utilize Class I 

34 deep-well injection for disposal of brine and other liquid wastes (Strata, 2011b). WDEQ has 

35 approved a UIC Class I Permit for up to five wells to be installed in the Deadwood and Flathead 

36 Formations (Permit No. 10-263) (WDEQ/WQD, 2011b). The Applicant expects the capacity of 

37 each of the five Class I wells to range between 132.5 – 302.8 L/min [35 – 80 gal/min]. The 

38 Applicant proposes a storage tank that, along with the lined impoundments, would provide surge 

39 capacity for management of the brine (Strata, 2012b).

40

41 Net annual evaporation of brine in the surface impoundments would be approximately 5.3 

42 L/min-ac [1.4 gal/min-ac] which would reduce the volume of brine injected in the disposal wells 

43 (Strata, 2011b). The Applicant estimates typical flow rates of brine mixed with other byproduct 

44 liquid waste to the deep-disposal wells of 235 L/min [62 gal/min] during the operation-only 

45 phase; 859 L/min [227 gal/min] during the phase where the ISR facility is operating concurrently 

46 with aquifer restoration; and 719 L/min [190 gal/min] during the aquifer-restoration-only phase 

47 (Strata, 2011a). Brine produced during decontamination and decommissioning would be less 
DRAFT In Situ Uranium Recovery and Alternatives

2-41

1 than 38 L/min [10 gal/min] (Strata, 2011a). The Applicant’s estimated flow rate of brine, 

2 permeate, and other liquid wastes for disposal would be less than noted in the GEIS (Table 2.7-

3 3) (NRC, 2009). 

4

5 The following non-byproduct (non-radioactive) liquid wastes would be generated at the Ross 

6 Project:

7

8 ■ Storm water from the paved areas of the proposed Ross Project facility

9 ■ Domestic sewage from the proposed facility

10 ■ Drilling fluids from construction of the proposed wellfields

11

12 Storm-water management would be controlled under a WYPDES Permit from WDEQ. As part 

13 of this permit, best management practices (BMPs) would be developed to restrict contaminants 

14 from the surface water and storm drains. Runoff from the facility would be diverted by the 

15 storm-drain system to a sediment surface impoundment near the CPP (Strata, 2011b). 

16

17 The Applicant estimates that the volume of domestic sewage would range between 1,100 L/d 

18 [300 gal/d] and 4,500 L/d [2,600 gal/d] depending upon the number of workers during each 

19 project phase (Strata, 2012a). Domestic waste water would be collected in a gravity-sewer 

20 collection system serving the administration building, CPP, maintenance building, and any other 

21 buildings or structures with restrooms. This system would be designed according to 

22 WDEQ/WQD standards and would include one or more septic tanks for primary treatment. 

23 Septic-tank effluent would be disposed in a drainfield or in an enhanced treatment system 

24 (Strata, 2011b). 

25

26 Drilling fluids of ground water and drilling muds would be produced only during the construction 

27 phase from the drilling and development of injection, recovery, and monitoring wells. The 

Applicant estimates that a volume of 22,000 L [6,000 gal] of water and 12 m3 [15 yd3 28 ] of drilling 

29 muds would be produced per well. The fluid would be stored onsite in mud pits constructed 

30 adjacent to the respective drilling pad(s) and evaporated. The Applicant expects the production 

31 of ground water during operation and decommissioning from wells completed outside of the 

32 aquifer exempted for uranium recovery (Strata, 2011a). This ground water would be discharged 

33 under a temporary WYPDES Permit. The Applicant was authorized to discharge these fluids 

34 under a temporary WYPDES Permit (No. WYG720229) issued during installation and sampling 

35 of monitoring wells (WDEQ/WQD, 2011a). This Permit was renewed in December 2012.

36

37 Solid Effluents

38

39 The GEIS describes the solid-phase wastes that would be generated during all phases of 

40 uranium-recovery operations. These solid wastes would be hazardous, radioactive, or typical 

41 solid waste. The projections of solid-waste generation and management methods proposed by 

42 the Applicant for the Proposed Action are within the industry standards described in Section 2.7 

43 of the GEIS (Strata, 2011b; Strata, 2012b; NRC, 2009). The Applicant provides a list of 

44 anticipated waste disposal facilities with adequate capacity that could be used for waste 

45 generated at the Ross Project (Strata, 2012a).
DRAFT In Situ Uranium Recovery and Alternatives

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1 The Applicant estimates the production of 19 L/mo [5 gal/mo] of used oil and less than 9 kg/mo 

2 [20 lb/mo] of used oil filters and oily rags. These wastes would be stored in a designated used3 oil storage area and would be shipped to a commercial recycling facility for disposal, such as 

4 Tri-State Recycling Services, Newcastle, Wyoming (Strata, 2012a). Petroleum-contaminated 

soil, estimated as less than 1 m3

/wk [1 yd3 5 /wk], would be transported by a waste-disposal 

6 contractor to a permitted land farm in northeast Wyoming such as the Campbell County Landfill 

7 (Strata, 2012a).

8

9 Less than 100 kg/mo [220 lb/mo] of waste designated as hazardous by the EPA and WDEQ, 

10 such as used batteries, expired laboratory reagents, burnt-out fluorescent light bulbs, spent 

11 solvents, certain cleaners, and used degreasers, would also be generated (Strata, 2012a). The 

12 hazardous waste would be stored at the Ross Project in secure, specially designed containers 

13 inside the maintenance shop. The Applicant expects the Ross Project to be classified as a 

14 conditionally exempt small quantity generator (known as a CESQG) of hazardous waste (Strata, 

15 2011b). Hazardous waste would be transported by a hazardous waste contractor to an 

16 appropriately permitted commercial recycling facility outside Wyoming (Strata, 2012a). The 

17 Applicant proposes onsite disposal contaminated laboratory reagents in the lined retention 

18 impoundments and deep-well injection (Strata, 2012a).

19

20 Radioactive byproduct solid waste that would be generated at the Ross Project include filtrate 

21 and spent filter media from production and restoration circuits; general sludge, scale, etc. from 

22 maintenance operations; affected soil collected from any spill or leak areas; spent/damaged ion 

23 exchange resin; well solids from injection/recovery well work-over operations; contaminated 

24 PPE; wellfield decommissioning waste such as pipelines, pumps, and impacted soil; affected 

25 concrete floors, sumps and berms in the CPP; equipment and piping in the CPP; pond sludge, 

26 pond liners, and leak detection systems; and disposal well piping and equipment (Strata, 

27 2012a). Byproduct solid wastes would be generated during all Proposed Action phases, except 

28 construction. During facility operation and aquifer restoration, the Applicant estimates the 

production of 80 m3

/yr [100 yd3 29 /yr] of solid byproduct waste. The largest volumes of byproduct 

30 waste, including contaminated soil requiring licensed disposal, would be generated during

facility decommissioning, which is estimated to be 4,000 m3 [5,000 yd3 31 ] (Strata, 2012a). The 

32 Applicant has identified four facilities with sufficient capability located in Wyoming, Utah, and 

33 Texas that are permitted to accept byproduct waste from ISR facilities (Strata, 2012a).

34

35 During all phases of the Proposed Action, when any byproduct wastes are generated, they 

36 would be stored inside a locked and posted room within the CPP (i.e., this area would be a 

37 restricted area). The wastes would be placed inside 208-L [55-gal], lined drums, sealed and 

placed inside a 15-m3 [20-yd3 38 ] roll-off container. The sealed roll-off containers containing the 

39 waste would be transported by a licensed transporter to a licensed radioactive waste facility for 

40 disposal. The Applicant anticipates about five annual shipments of byproduct wastes during the 

41 facility-operation and aquifer-restoration phases. During decommissioning, which is expected to 

42 last 12 to 18 months, up to 200 shipments per year would be expected (Strata, 2011b).

43

44 Non byproduct solid wastes generated at the Ross Project include ordinary trash, petroleum45 contaminated soil, construction debris, and decontaminated material and equipment. The 

Applicant estimates that 12 m3

/wk [15 yd3 46 /wk] of ordinary municipal solid waste such as office 

trash along with 4 m3

/wk [5 yd3 47 /wk] of recyclable wastes (plastic, glass, paper, aluminum, and 

48 cardboard) would be generated throughout the life of the Ross Project (Strata, 2012b). Small 

amounts (less than 0.8 m3

/wk [5 yd3 49 /wk]) of petroleum-contaminated soil would also be 
DRAFT In Situ Uranium Recovery and Alternatives

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1 generated. The generation of solid waste consisting of construction debris and decontaminated 

materials and equipment would be less than 4 m3

/wk [5 yd3 2 /wk] during facility construction and 

3 operation, and aquifer restoration. During the decommissioning phase, the Applicant estimates 

up to 1,500 m3 [2,000 yd3 4 ] of such solid waste (Strata, 2012a). 

5

6 During facility operation and aquifer restoration, non-hazardous solid wastes would be collected 

7 daily from work areas and disposed in trash receptacles located within the facility, but near a 

8 primary access road for convenient access for a waste-disposal contractor. Non-hazardous 

9 solid waste would be disposed offsite in the Moorcroft landfill or the Campbell County landfill in 

10 Gillette, Wyoming (Strata, 2011a). Solid waste of construction and demolition debris would be 

11 disposed in the municipal or country landfills in the three towns nearest the Ross Project: 

12 Moorcroft, Sundance, and Gillette.

13

14 2.1.1.6 Transportation

15

16 Primary transportation activities would involve truck shipping and personnel commuting. A 

17 variety of truck shipments are planned to support proposed activities during all phases of the 

18 Proposed Action. Light-duty trucks and automobiles would transport construction contractors 

19 and the operations workforce. Baseline transportation conditions and impact of the Ross 

20 Project are discussed in SEIS Sections 3.3 and 4.3, respectively.

21

22 Transportation routes within 80 km [50 mi] of the Proposed Action include interstate highways, 

23 other U.S. highways, Wyoming highways, county roads, and local roads (Strata, 2011a). The 

24 major transportation corridors that could be used to access the Ross Project area include 

25 Interstate-90, approximately 32 km [20 mi] south; U.S. Highway 14, approximately 16 km [10 mi] 

26 southeast; State Highway 59, approximately 32 km [20 mi] west; and U.S. Highway 212, 

27 approximately 64 km [40 mi] northeast. Regional and local transportation routes are shown on 

28 Figure 2.1. 

29 The primary access to the Ross Project area is from D Road [CR 68] from the New Haven Road 

30 (CR 164). The primary access road to the ISR facility would be constructed to flow from New 

31 Haven Road (CR 164). The design of the road includes a 9 m [30 ft] top width with 5 horizontal 

32 to 1 vertical side slopes. According to American Association of State Highway and 

33 Transportation Officials (AASHTO), a 5:1 slope is traversable and recoverable; therefore, no 

34 guardrails would be used on the access road (AASHTO, 2002; Strata, 2011b).

35

36 2.1.1.7 Financial Surety

37

38 Prior to commencement of operations, the Applicant would be required to provide assurance 

39 that sufficient funds will be available to cover decontamination, dismantling, and 

40 decommissioning as well as to cover aquifer restoration of the Ross Project, including all costs 

41 of site reclamation and decommissioning waste disposal (10 CFR Part 40, Appendix A, Criterion 

42 [9]). A decommissioning funding plan (DFP) would be required from the Applicant as an NRC 

43 license condition; the DFP would contain a decommissioning cost estimate, the amount of which 

44 the Applicant would be required to maintain in a financial-surety arrangement. The initial 

45 decommissioning cost estimate would be based upon the first year of operation, which includes 

46 the construction of the CPP, and would be fully described in the DFP. NRC license conditions 

47 and the WDEQ/LQD Permit to Mine would also require, on a forward-looking basis, annual 

48 revisions to the decommissioning cost estimate and the related financial surety. When NRC, 
DRAFT In Situ Uranium Recovery and Alternatives

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1 WDEQ, and the Applicant have agreed to the initial cost estimate and DFP, the Applicant would 

2 submit a surety instrument acceptable to both NRC and WDEQ. Details of NRC’s requirement 

3 for financial surety would be part of the Safety Evaluation Report (SER) for the Ross Project and 

4 the surety would be required by the Applicant’s NRC license. The Applicant would be required 

5 to maintain these surety arrangements until the NRC determined that the Applicant had

6 complied with its reclamation plan. For additional information on decommissioning funding 

7 plans and financial-surety requirements, see 10 CFR Part 40, Appendix A; NUREG–1757, 

8 Consolidated NMSS Decommissioning Guidance; and the GEIS in Section 2.10 (NRC, 2003b; 

9 NRC, 2009). 

10

11 2.1.2 Alternative 2: No Action

12

13 Under the No-Action Alternative, the NRC would not issue a license for the proposed ISR 

14 project and BLM would not approve the Applicant’s Plan of Operations (POO). The No-Action 

15 Alternative would result in the Applicant’s not constructing, operating, restoring the aquifer of, or 

16 decommissioning the proposed ISR project. However, even if the proposed Ross Project is not 

17 licensed, the Applicant has already accomplished certain preconstruction activities that do not 

18 require an NRC license or BLM POO at the Ross Project area. At no time would radioactive 

19 materials be present at the Ross Project during any preconstruction activities. These previously 

20 completed preconstruction activities are evaluated as part of Alternative 2: No Action.

21

22 Preconstruction activities that have already been accomplished include the Applicant’s locating 

23 and properly abandoning the former Nubeth’s exploration drillholes. As of October 2010, the 

24 Applicant has located 759 of the 1682 holes thought to exist from Nubeth exploration activities 

25 and has plugged 55 of them (Strata, 2011b). In addition, Strata has drilled and then properly 

26 abandoned 512 holes used to delineate the ore zone. The Applicant has also drilled and 

27 completed 51 wells for ground-water monitoring and testing (Strata, 2011a) as well as installed 

28 3 surface-water monitoring stations and a meteorology station. Data collection activities from 

29 the ground-water wells, surface-water stations, and the meteorological station are continuing. In 

30 August 2011, an additional 74 drillholes and 4 ground-water monitoring wells were installed to 

31 support a geotechnical investigation of the area proposed for the Ross Project (Strata, 2012b). 

32 These drillholes have also been properly plugged and abandoned, and the four ground-water 

33 monitoring wells are being used for ongoing ground-water monitoring. Finally, a ranch house 

34 that was present on the property has been remodeled to serve as the Applicant’s Field Office at 

35 the Ross Project area. 

36

37 In the No-Action Alternative, no uranium would be allowed to be recovered from the subsurface 

38 ore zone, and no injection, production, or monitoring wells would be installed. No lixiviant would 

39 be introduced to the subsurface, and no recovered uranium would be extracted and no facilities 

40 would be constructed to process extracted uranium or store chemicals. The No-Action 

41 Alternative is included to provide a benchmark for the NRC to compare and evaluate the 

42 potential impacts of the other alternatives, including the Proposed Action.

43

44 2.1.3 Alternative 3: North Ross Project

45

46 Under Alternative 3, the NRC would issue the Applicant a license for the construction, operation, 

47 aquifer restoration, and decommissioning of the proposed ISR project, except that the entire ISR 

48 facility itself, which includes all buildings, other auxiliary structures, and the surface impoundments 

49 would be located north of where it is to be situated during the Proposed Action, but the locations of 
DRAFT In Situ Uranium Recovery and Alternatives

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1 the wellfields would not change. This alternate location for the ISR facility, referred as the “north 

2 site” by the Applicant (and referred to herein as the “North Ross Project”), was considered, but 

3 eliminated, by the Applicant in its license application (Strata, 2011a). The north site is located 

4 about 240 m [800 ft] north of the Oshoto Reservoir in S1⁄2SW1⁄4 Section 7, T53N, R67W (see 

5 Figure 2.11). It is about 900 m [3,000 ft] northwest of where the facility would be located in the 

6 Proposed Action (referred to by the Applicant as the “south site”). An unnamed surface water 

7 drainage feature generally divides the north site. To avoid the floodplain of the drainage an 

8 actual design of the facility at this site would likely place the CPP and other buildings on one 

9 side of the drainage and the surface impoundments on the other side.

10

11 The Applicant documents its decision to select the south site over the north site with the 

12 following comparisons (Strata, 2011a):

13

14 ■ The south site is situated on relatively flat topography, which would minimize the amount of 

15 earthwork and surface disturbance required to prepare the site for construction of the CPP, 

16 auxiliary buildings, surface impoundments, and parking areas. 

17 ■ The south site’s surface is entirely privately owned and onsite instrumentation is currently 

18 adequate for all required pre-operational baseline environmental studies (see 10 CFR Part

19 40, Appendix A). 

20 ■ The south site has little uranium mineralization beneath it, and what there is would be 

21 accessible without major modification of the wellfield- and monitoring-well layout. 

22 ■ The preliminary geotechnical studies at the south site indicate that subsoil materials are 

23 relatively impermeable and have adequate strength for the proposed buildings and 

24 structures. 

25 ■ The preliminary estimates of the radionuclide release rates from the entire project, including 

26 the south site, indicates that the average annual radiation dose to the nearest receptor 

27 would be less than 5 percent of the NRC’s 1 mSv/yr [100 mrem/yr] annual limit. 

28 ■ The owner of the south site is also the owner of the Oshoto Reservoir, so a surface-use 

29 agreement, lease, or purchase of this area would afford Strata control over the Reservoir as 

30 well.

31

32 The North Ross Project is included as an Alternative in this SEIS because of the expected 

33 differences in the depth to ground water between the north and south sites. Based upon the 

34 water levels measured in a nearby well cluster, Well No. 12-18, and the surface topography, 

35 shallow ground water of the north site is likely to be greater than 15 m [50 ft] below the ground 

36 surface (Strata, 2011a). In contrast, shallow ground water beneath the south site ranges from 2 

37 – 4 m [8 – 12 ft] below the ground surface and necessitates the construction of the CBW (Strata, 

38 2011b). 

39

40 Certain factors related to the north site as a location for the proposed Ross Project facility are 

41 considered in this SEIS’s impact analyses. These factors include:

42 ■ The north site’s deeper ground-water levels, which could eliminate the need for a CBW and 

43 dewatering in order to protect ground water.
DRAFT In Situ Uranium Recovery and Alternatives

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1 ■ The north site’s more pronounced topography, which could require more earthwork and 

2 surface disturbance for construction of the facility and surface impoundments.

3 ■ The north site’s greater distance to the Little Missouri River, which could mitigate potential 

4 impacts on surface-water resources.

5 ■ The north site’s natural screen provided by the ridges to the west, north, and east, which 

6 could decrease impacts on visual and scenic resources.

7 ■ The north site’s increased uranium mineralization beneath it, which could potentially require 

8 a reconfiguration of the facility to allow uranium recovery.

9

10 2.2 Alternatives Eliminated from Detailed Analysis

11

12 This section describes alternatives to the Proposed Action that were considered for this SEIS, 

13 but were not carried forward for detailed analysis. Section 2.2.1 describes the recovery of 

14 uranium by conventional mining and milling; Section 2.2.2 discusses the use of a lixiviant with 

15 different chemistry; and Section 2.2.3 compares alternative methods of waste management.

16

17 2.2.1 Conventional Mining and Milling

18

19 The GEIS includes an evaluation of conventional mining and milling as an alternative to ISR 

20 (NRC, 2009). Although the characteristics of the uranium deposits of the proposed Ross 

21 Project are amenable to ISR extraction, evaluating the Proposed Action against the 

22 conventional mining and milling allows comparison of impacts of the two uranium-recovery 

23 methods. Conventional mining practices (open-pit and underground) to recover uranium ore in 

24 addition to conventional milling were considered and eliminated as an alternative to ISR 

25 operations at the proposed Ross Project, as they were in the GEIS (NRC, 2009; Strata, 2011a). 

26

27 Conventional mining refers to the physical removal of uranium ore by either underground mining 

28 methods or from an open pit. Uranium is extracted and converted to yellowcake in a processing 

29 facility; this process is referred to as uranium “milling.” Open-pit mining is suitable for shallow 

30 ore deposits, generally deposits less than 170 m [550 ft] below ground surface (bgs), such as 

31 those found at the Ross Project area. 

32

33 Underground mining could be used for deeper deposits; however, the cost of underground 

34 mining and milling requires a higher grade of ore to be economically feasible compared to open 

35 pit-mining and ISR (EPA, 2008). Uranium-ore grade in the Lance District is low-grade (Strata, 

36 2011a; Peninsula, 2011). The ore zone at the Ross Project is approximately 30 – 60 m [90 –

37 180 ft] thick (Strata, 2011b). The base of the ore is generally at depths of 150 – 200 m [500 –

38 700 ft], which is nearly the maximum depth for surface mining to practically recover uranium 

39 from an open pit. 

40 In addition to the depths involved with open-pit mining, water consumption of open-pit mining 

41 likely would be greater than at an ISR facility because of the required dewatering down to the 

42 depth of the pit’s floor. At the Ross Project, dewatering of several aquifers above the ore zone 

43 and the ore zone itself would be required for open-pit mining and large amounts of water would 

44 be produced (Strata, 2011a). 
DRAFT In Situ Uranium Recovery and Alternatives

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1

2

3

Figure 2.11

Alternative 3: North Ross Project

(CPP on Right and Surface Impoundments on Left)

Source: Strata, 2012a
DRAFT In Situ Uranium Recovery and Alternatives

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1 Far greater areas of land disturbance would occur from an open-pit mine compared with the 

2 Ross Project and the required restoration of the open pit would be far more extensive. Even 

3 though overburden could be backfilled into the pit, the pit would permanently impact the 

4 surface’s appearance and its land use. 

5

6 Conventional uranium milling requires construction of a facility that would be larger than the 

7 proposed facility at the Ross Project. As described in Appendix C of the GEIS (NRC, 2009), ore 

8 processing at a conventional uranium mill involves a series of steps (handling and preparation, 

9 concentration, and product recovery). Uranium ore is crushed, ground, and classified to 

10 produce uniform-sized particles (EPA, 2008). After grinding, the ore is added to a series of 

11 tanks for leaching by a lixiviant similar to that proposed by the Applicant for the Ross Project. 

12 The precipitation of uranium from the pregnant lixiviant, drying the product, and packaging the 

13 yellowcake follow the same processes as proposed for the Ross Project. Emissions containing 

14 radiological constituents generated by handling, grinding, and classifying the ores creates the 

15 potential for greater impacts to the health and safety of workers. 

16 Wastes generated by milling include the spent ore, which are referred to as “tailings.” The 

17 volume of tailings is roughly 95 percent of the volume of the ore brought to the mill. Wastes 

18 from conventional uranium milling, such as well waste water, spent resins, and filtrate, would be 

19 the same as the wastes generated by Applicant’s proposed processing of pregnant lixiviant from 

20 ISR wellfields.

21

22 Wet tailings are disposed in surface impoundments constructed with liners and covers to 

23 prevent escape to the environment. Although the chemical character of tailings depends upon 

24 the uranium ore and lixiviant, tailings generally contain soluble metals, radium, and high levels 

25 of dissolved solids. Reclamation of a tailings pile generally involves evaporation of any liquid in 

26 the tailings, settlement of the tailings over time, and protection of the pile with a thick radon 

27 barrier and earthen material or rocks for erosion control. An area surrounding the reclaimed 

28 tailings piles would be fenced off in perpetuity, and the site transferred to either a State or 

29 Federal agency for long-term care (EIA, 1995).

30

31 As an alternative to conventional milling, uranium from low-grade ore that is recovered by open32 pit mining can be recovered by heap leaching. Heap leaching occurs at or very near the mine 

33 site itself. The low-grade ore is crushed to a fine size and mounded above grade on a prepared 

34 pad. A sprinkler or drip system distributes lixiviant over the mound. The lixiviant trickles 

35 through the ore and mobilizes uranium into solution. The solution is collected at the base of the 

36 mound and processed to produce yellowcake. The processing to yellowcake of the pregnant 

37 lixiviant would be the same as for the Ross Project.

38

39 Given the uranium ore grade and depth to the ore, open-pit mining and conventional milling 

40 would be possible at the Ross Project; however, the costs, environmental impacts, and potential 

41 health and safety impacts to workers are more substantial than impacts from the ISR process 

42 (see SEIS Section 4).

43

44 As noted in the GEIS on uranium milling (NRC, 1980b), besides cost considerations, the 

45 environmental impacts of open-pit mining, and tailings impoundment would be greater than from 

46 an ISR project. Greater impacts such as those listed below would affect land use and soils as 

47 well as ecological, water, and air resources. Some of these impacts are:
DRAFT In Situ Uranium Recovery and Alternatives

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1 ■ A larger area of surface disturbance for an open-pit mine and uranium mill, which could 

2 increase environmental impacts.

3 ■ A permanent tailings pile, which would require long-term care and maintenance to prevent 

4 impacts to air and water.

5 ■ A permanent mine pit if an open-pit mining were to be used, into which groundwater would 

6 flow creating a lake of poor water quality.

7 ■ A greater consumptive water use, which would result from the ground water’s intruding into 

8 the mine and its needing to be pumped (i.e., dewatered) with the excess water then 

9 discharged to the environment.

10 ■ A greater surface discharge of water, which would result from the pumping and treatment of 

11 excess water from the mine pit.

12 The mine workers’ excavating the uranium ore during the mining operation, through the uranium 

13 milling process itself, and the disposal of the tailings also increase the potential impacts to 

14 workers’ health and safety. 

15

16 Based upon these greater impacts, the alternatives of conventional uranium mining and milling 

17 have been eliminated from further analysis in this SEIS.

18

19 2.2.2 Alternate Lixiviant Chemistry

20

21 The lixiviant proposed for the Ross Project is consistent with the assumption in the GEIS that 

22 the ISR process would employ alkaline lixiviants (NRC, 2009). Alkaline solutions are typically 

23 used to dissolve uranium in the ore zone when the lime content of the host rock in the ore zone 

24 is above 12 percent, which is the case for the Ross Project site (Strata, 2011b). Other lixiviants 

25 can be made with sulfuric acid or ammonia, and these have been shown to dissolve uranium

26 (NRC, 2009). However, the lixiviant that is selected for a specific ISR project must be able to 

27 dissolve uranium from the host rock while it maintains the permeability of the aquifer. In 

28 addition, the lixiviant and its reaction products must be amenable to ground-water restoration. 

29

30 Acidic lixiviant has been 

31 used most broadly in 

32 conventional milling. 

33 These acid-based fluids 

34 have generally achieved 

35 high yield and efficient, 

36 rapid uranium recovery, 

37 but they also dissolved 

38 other metals associated 

39 with the uranium in the 

40 host rock, and this 

41 dissolution can contribute 

42 to adverse environmental 

43 impacts. In Wyoming, acid 

44 lixiviants have been 

How do you select a proper lixiviant?

The geology and ground-water chemistry determine the proper ISR 

techniques and chemical reagents used for uranium recovery. For 

example, if the ore-bearing aquifer is rich in calcium (e.g., limestone or 

gypsum), alkaline (carbonate), lixiviant might be used (Hunkin, 1977, as 

cited in NRC, 2009). Otherwise, an acid (sulfate) lixiviant might be 

preferable. The lixiviant chemistry chosen for ISR operations could affect 

the type of potential contamination and the vulnerability of aquifers during 

and after ISR operations.

Typical ISR operations in the U.S. use an alkaline sodium bicarbonate 

system to remove the uranium from ore-bearing aquifers. In addition, 

aquifers where an alkaline-based lixiviant was used were considered to be 

easier to restore than those where acid lixiviants were used (Tweeton and 

Peterson, 1981, and Mudd, 1998, as cited in NRC, 2009).
DRAFT In Situ Uranium Recovery and Alternatives

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1 used for small-scale research and development operations, but they have not been used in 

2 commercial operations (NRC, 2009). Tests with acid lixiviants have identified two major 

3 problems: 1) gypsum (a calcium mineral) precipitates on well screens and within the aquifer 

4 during uranium recovery, plugging wells and reducing the aquifer’s permeability, which is critical 

5 for economic operation; and 2) the precipitated gypsum gradually dissolves after aquifer 

6 restoration, increasing the salinity and sulfate levels in the ground water. Because of the 

7 potential impacts of soluble metals and increased salinity in the aquifer as well as the potential 

8 for plugging of the aquifer by their use, acid-based lixiviants have been eliminated from further 

9 analysis in this SEIS.

10

11 Ammonia-based lixiviants have been used at some ISR operations in Wyoming. However, 

12 operational experience has shown that ammonia tends to adsorb onto clay minerals in the ore 

13 zone and then slowly dissolves from the clay during aquifer restoration, therefore requiring that 

14 a much larger volume of ground water be removed and processed during the aquifer restoration 

15 phase (NRC, 2009). Traces of the ammonia from the lixiviant have remained in affected 

16 aquifers even after extensive aquifer restoration. Because of the greater consumption of ground 

17 water to meet aquifer-restoration requirements, the use of an ammonia-based lixiviant has been 

18 eliminated from further analysis in this SEIS.

19

20 2.2.3 Alternate Waste Management Methodologies

21

22 Liquid-effluent disposal practices that the NRC has previously approved for use at specific ISR 

23 sites include waste evaporation from surface impoundments, application of waste on land, 

24 injection of waste into deep wells, and discharge of waste to surface water (NRC, 2009).

25

26 The Proposed Action would employ injection into a UIC-permitted Class I well as the primary 

27 method of disposal of the brine and other process waste waters excluding permeate from the 

28 RO process. The Proposed Action would include surface impoundments located near the CPP 

29 to store and manage the brine and to allow reuse of permeate as lixiviant or process water. Of 

30 the approximately 6.5 ha [16 ac] of impoundment surface area in the Proposed Action, 2.5 ha 

31 [6.3 ac] would be available for evaporation (Strata, 2011b). The Applicant predicts that the 

32 evaporation of brine during the time it is stored in the surface impoundments would reduce the 

33 volume for deep disposal by 20 percent during the operation-only phase and about 5 percent 

34 during the concurrent operation- and aquifer-restoration phases. Excess permeate while stored 

35 in the surface impoundments would evaporate at an average annual rate of 1.5 gpm per surface 

36 acre (Strata, 2012b). 

37

38 Reliance on evaporation to dispose of all the brine and other liquid byproduct wastes generated 

39 at the CPP, and thus eliminating the need for deep-well injection, would require a larger surface 

40 area of the impoundments. The maximum production of brine and other process waste occurs 

41 during the concurrent facility operation and aquifer-restoration phases. During this time, 859 

42 L/min [227 gal/min] of byproduct liquid would be generated (Strata, 2011a). The remaining 

43 surface-impoundment volume in the Proposed Action would be used for permeate management 

44 and reserve capacity in the event of upset conditions.

45

46 The Applicant has estimated that the 2.5 ha [6.3 ac] available for evaporation in the Proposed 

47 Action would provide 33.3 L/min [8.8 gal/min] of average annual evaporation. Linear 

48 extrapolation suggests that 65 ha [160 ac] is the minimum surface area required for evaporation 

49 of all brine and other byproduct waste generated at the CPP. Considering the requirement to 
DRAFT In Situ Uranium Recovery and Alternatives

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1 maintain reserve capacity to manage upset conditions and the natural fluctuations, the 

2 necessary surface impoundments would exceed 80 ha [200 ac]. Impoundments of sufficient 

3 size to eliminate the need for deep-well injection would nearly double the disturbed area. In the 

4 Proposed Action, approximately 113 ha [280 ac] would be disturbed during the entire Ross 

5 Project. The disturbed area required for only evaporation would be present throughout the 

6 entire construction, operation, aquifer restoration and decommissioning phases. It is likely that 

7 the CBW would need to be constructed around these large surface impoundments. Because 

8 the CPP and the surface impoundments would be expected to remain operational after the life 

9 of the proposed wellfields of the Ross Project, the surface impoundments would likely be in 

10 place for more than 10 years. 

11

12 These large-scale surface impoundments could potentially impact land use and soils as well as 

13 ecological, water, air, and visual resources. These impacts and related occupational health 

14 impacts could require mitigation. In contrast, the GEIS concluded that the permit process 

15 required for a Class I injection well provides confidence that the impacts from deep-well disposal 

16 would be SMALL. For these reasons, the alternative of the elimination of waste disposal in 

17 Class I deep-injection wells in favor of surface impoundments over more than 12 times the area 

18 of impoundments in the Proposed Action has not been carried forward for impact analysis in this 

19 SEIS. 

20

21 2.3 Comparison of Predicted Environmental Impacts

22 The GEIS categorized the

23 significance of potential

24 environmental impacts as

25 described in the adjacent text 

26 box (NRC, 2009). The large 

27 table, presented in the 

28 “Executive Summary” as 

29 Table ExS.1, summarizes the

30 potential environmental

31 impacts to each resource

32 area for all four of the Ross 

33 Project’s phases:

34 construction, operation, aquifer restoration, and decommissioning. The levels of significance—

35 SMALL, MODERATE, and LARGE—are noted for each resource area. 

36

37 The respective resource areas, as they currently exist at the Ross Project area, which is called 

38 the “affected environment,” are described in Section 3 of this SEIS. The potential environmental

39 impacts of the Ross Project are evaluated in Section 4 of this SEIS. The measures intended to 

40 mitigate any impacts are also discussed in SEIS Section 4 of this SEIS.

41

42 2.4 Preliminary Recommendation

43

44 After weighing the impacts of the Proposed Action and comparing the Alternatives, the NRC 

45 staff, in accordance with 10 CFR Part 51.71(f), sets forth its preliminary NEPA recommendation

46 regarding the Proposed Action. Unless safety issues mandate otherwise, the preliminary NRC

47 staff recommendation to the Commission related to the environmental aspects of the Proposed 

48 Action is that a source and byproduct materials license for the Proposed Action be issued as

How is the significance of identified impacts classified?

■ Small Impact: The environmental effects are not detectable or 

are so minor that they will neither destabilize nor noticeably alter 

any important attribute of the resource considered.

■ Moderate Impact: The environmental effects are sufficient to 

alter noticeably, but not destabilize, important attributes of the 

resource considered.

■ Large Impact: The environmental effects are clearly noticeable 

and are sufficient to destabilize important attributes of the 

resource considered.
DRAFT In Situ Uranium Recovery and Alternatives

2-52

1 requested. The NRC staff concludes that the applicable environmental monitoring program 

2 described in Chapter 6 and the proposed mitigation measures discussed in Chapter 4 will 

3 eliminate or substantially lessen the potential adverse environmental impacts associated with 

4 the Proposed Action. 

5

6 The NRC staff has concluded that the overall benefits of the proposed action outweigh the 

7 environmental disadvantages and costs based on consideration of the following:

8

9 • Potential adverse impacts to all environmental resource areas are expected to be SMALL, 

10 with the exception of

11

12 1. Transportation resources during all phases of the proposed action. Increases in traffic 

13 during construction and operation would have a MODERATE to LARGE impact. 

14 Impacts would be MODERATE with mitigation for construction, operation, aquifer 

15 restoration, and decommissioning (See SEIS Sections 4.3.1.1, 4.3.1.2, 4.3.1.3, and 

16 4.3.1.4). 

17

18 2. Groundwater resources during operation and aquifer restoration. During operations 

19 there would be a MODERATE impact to ore-zone aquifer water quality due to 

20 excursions; however with measures in place to detect and resolve the excursions, the 

21 impacts would be reduced. During aquifer restoration there would be a MODERATE 

22 impact to ore-zone aquifer water quantity due to short-term drawdown (See SEIS 

23 Sections 4.5.1.2 and 4.5.1.3). 

24

25 3. Noise resources during construction, operations, and decommissioning. During these 

26 phases of the Ross Project there would be MODERATE impacts due to increased noise 

27 levels, however they would be intermittent and short term (See SEIS Sections 4.8.1.1, 

28 4.8.1.2 and 4.8.1.4). 

29

30 4. Historical and cultural resources during construction. Section 106 consultation and 

31 efforts to identify and determine the eligibility of historical and cultural resources that 

32 could be adversely affected by the proposed Ross Project are currently ongoing. 

33 Therefore, to be conservative in this draft SEIS, the NRC staff considers that 

34 construction could have a MODERATE to LARGE impact on historic properties, sites 

35 currently listed or eligible for listing on the National Register of Historic Places (NRHP)—

36 and other unevaluated historic, cultural, and religious properties in the project area (See 

37 SEIS Section 4.9.1.1). However, once identification efforts are complete, mitigation 

38 efforts, which could require an MOA, would be developed to reduce impacts. The final 

39 SEIS will include the outcome of Section 106 consultation and would discuss mitigation 

40 measures, including an MOA, if one is developed. 

41

42 5. Visual and scenic resources during construction. There would be MODERATE impacts 

43 to residents near the Ross Project for the first year, however over the long term, impacts 

44 would be reduced (See SEIS Section 4.10.1.1).

45

46 6. Socioeconomic resources during construction and operations. There would be 

47 MODERATE impacts to Crook County during these phases of the Ross Project because 

48 taxes from the Project will be paid to the county (See Sections 4.11.1.1 and 4.11.1.2).

49
DRAFT In Situ Uranium Recovery and Alternatives

2-53

1 • Regarding groundwater, the portion of the aquifer(s) designated for uranium recovery must 

2 be exempted as underground sources of drinking water before ISR operations begin. 

3 Additionally, Strata would be required to monitor for excursions of lixiviant from the 

4 production zones and to take corrective actions in the event of an excursion. Prior to 

5 operations, the Applicant would be required to provide detailed hydrologic pumping test data 

6 packages and operational plans for each wellfield at the Ross Project. Strata would also be 

7 required to restore groundwater parameters affected by the ISR operations to levels that are 

8 protective of human health and safety. 

9

10 • The costs associated with the Ross Project are, for the most part, limited to the area 

11 surrounding the site. 

12

13 • The regional benefits of building the proposed Project would be: increased employment, 

14 economic activity, and tax revenues in the region around the proposed Project site.

15

16 2.5 References

17

18 10 CFR Part 20. Title 10, “Energy,” Code of Federal Regulations, Part 20, “Standards for 

19 Protection Against Radiation,” Subpart K, “Waste Disposal.” Washington, DC: Government 

20 Printing Office. 1991, as amended.

21

22 10 CFR Part 40. Title 10, “Energy,” Code of Federal Regulations, Part 40, “Domestic Licensing 

23 of Source Material,” Appendix A, “Criteria Relating to the Operation of Uranium Mills and the 

24 Disposition of Tailings or Wastes Produced by the Extraction or Concentration of Source 

25 Material from Ores Processed Primarily for their Source Material Content.” Washington, DC: 

26 Government Printing Office. 1985, as amended. 

27

28 10 CFR Part 40. Title 10, “Energy,” Code of Federal Regulations, Part 40, “Domestic Licensing 

29 of Source Material.” Washington, DC: Government Printing Office. 1961, as amended. 

30

31 40 CFR Part 145. Title 40, “Protection of the Environment,” Code of Federal Regulations, Part 

32 145, “State UIC Program Requirements.” Washington, DC: Government Printing Office. 1983, 

33 as amended. 

34

35 40 CFR Part 146. Title 40, “Protection of the Environment,” Code of Federal Regulations, Part 

36 146, “Underground Injection Control Program: Criteria and Standards.” Washington, DC: 

37 Government Printing Office. 1980, as amended. 

38

39 (US)EIA (U. S. Energy Information Administration). Decommissioning of U.S. Uranium 

40 Production Facilities. DOE/EIA-0592. Washington, DC: Office of Coal, Nuclear, Electric, and 

41 Alternate Fuels, EIA. February 1995. Agencywide Documents Access and Management 

42 System (ADAMS) Accession No. ML13011A269. 

43

44 (US)EIA. 2011 Domestic Uranium Production Report. Washington, DC: Office of Electricity, 

45 Renewables, and Uranium Statistics, EIA. May 2012. ADAMS Accession No. ML13011A271. 

46

47 (US)EPA (U.S. Environmental Protection Agency). Technical Report on Technologically 

48 Enhanced Naturally Occurring Radioactive Materials from Uranium Mining: Mining and 
DRAFT In Situ Uranium Recovery and Alternatives

2-54

1 Reclamation Background. Volume 1. EPA–402–R–08–005. Washington, DC: Office of 

2 Radiation and Indoor Air/Radiation Protection Division, USEPA. 2008. ADAMS Accession No. 

3 ML13015A579. 

4

5 (US)NRC (U.S. Nuclear Regulatory Commission). Operational Inspection and Surveillance of 

6 Embankment Retention Systems for Uranium Mill Tailings. Regulatory Guide 3.11.1, Revision 

7 1. Washington, DC: USNRC. October 1980a. 

8

9 (US)NRC. NUREG–0706. “Final Generic Environmental Impact Statement on Uranium Milling 

10 Project M-25.” Washington, DC: NRC. September 1980b. ADAMS Accession Nos.

11 ML032751663, ML0732751667, and ML032751669. 

12

13 (US)NRC. Residual Radioactive Contamination From Decommissioning. Volumes 1, 2, 3, and 

14 4. NUREG–CR-5512. Washington, DC: USNRC. October 1999. 

15

16 (US)NRC. Standard Review Plan for In Situ Leach Uranium Extraction License Applications, 

17 Final Report. NUREG–1569. Washington, DC: USNRC. June 2003a. ADAMS Accession No. 

18 ML032250177. 

19

20 (US)NRC. Consolidated NMSS Decommissioning Guidance/Decommissioning Process for 

21 Materials Licensees. Volumes 1 Rev. 2, 2, and 3 Rev. 1. NUREG–1757. Washington, DC: 

22 USNRC. September 2003b. ADAMS Accession Nos. ML063000243, ML053260027, and 

23 ML12048A683. 

24

25 (US)NRC. Generic Environmental Impact Statement for In-Situ Leach Uranium Milling 

26 Facilities. Volumes 1 and 2. NUREG–1910. Washington, DC: USNRC. May 2009. ADAMS 

27 Accession Nos. ML091480244 and ML091480188. 

28

29 (US)NRC. “Site Visit and Informal Information Gathering Meetings Summary Report for 

30 the Proposed Ross In-Situ Recovery Project (Docket No. 040-09091).” Memorandum to 

31 K. Hsueh, Branch Chief, from A. Bjornsen, Project Manager, Office of Federal and State 

32 Materials and Environmental Management Programs. November 28, 2011. Washington, 

33 DC: USNRC. 2011. ADAMS Accession Nos. ML112980194. 

34

35 Peninsula Energy, Ltd. “Lance Project, Wyoming.” 2011. At www.pel.net.au/projects/lance_

36 project_wyoming_usa.phtml (as of June 25, 2012). 

37

38 Strata (Strata Energy, Inc.) Ross ISR Project USNRC License Application, Crook County, 

39 Wyoming, Environmental Report, Volumes 1, 2 and 3 with Appendices. Docket No. 40-09091. 

40 Gillette, WY: Strata Energy, Inc. 2011a. ADAMS Accession Nos. ML110130342, 

41 ML110130344, and ML110130348. 

42

43 Strata. Ross ISR Project USNRC License Application, Crook County, Wyoming, Technical 

44 Report, Volumes 1 through 6 with Appendices. Docket No. 40-09091. Gillette, WY: Strata. 

45 2011b. ADAMS Accession Nos. ML110130333, ML110130335, ML110130314, ML110130316, 

46 ML110130320, and ML110130327. 
DRAFT In Situ Uranium Recovery and Alternatives

2-55

1 Strata. Ross ISR Project USNRC License Application, Crook County, Wyoming, RAI Question 

2 and Answer Responses, Environmental Report, Volume 1 with Appendices. Docket No. 40-

3 09091. Gillette, WY: Strata. 2012a. ADAMS Accession No. ML121030465. 

4

5 Strata. Ross ISR Project USNRC License Application, Crook County, Wyoming, RAI Question 

6 and Answer Responses, Technical Report, Volumes 1 and 2 with Appendices. Docket No. 40-

7 09091. Gillette, WY: Strata. 2012b. ADAMS Accession Nos. ML121020357 and 

8 ML121020361. 

9

10 WDEQ/LQD (Wyoming Department of Environmental Quality/Land Quality Division). “Noncoal 

11 In Situ Mining,” Rules and Regulations, Chapter 11. Cheyenne, WY: WDEQ/WQD. 2005.

12

13 WDEQ/WQD (Wyoming Department of Environmental Quality/Water Quality Division). “Design 

14 and Construction Standards for Sewage Systems, Treatment Works, Disposal Systems or other 

15 Facilities Capable of Causing or Contributing to Pollution.” Rules and Regulations, Chapter 11. 

16 Cheyenne, WY: WDEQ/WQD. 1984.

17

18 WDEQ/WQD. “Wyoming Surface Water Quality Standards,” Rules and Regulations, Chapter 1. 

19 Cheyenne, WY. WDEQ/WQD. 2007.

20

21 WDEQ/WQD. Authorization to Discharge Wastewater Associated with Pump Testing of Water 

22 Wells Under the Wyoming Pollutant Discharge Elimination System. Authorization 

23 #WYG720229. Cheyenne, WY: WDEQ/WQD. March 2011a. ADAMS Accession No. 

24 ML13015A695. 

25

26 WDEQ/WQD. Strata Energy, Inc. – Ross Disposal Injection Wellfield, Final Permit 10-263,

27 Class I Non-hazardous, Crook County, Wyoming. Cheyenne, WY: WDEQ/WQD. April 2011b. 

28

29 WWC Engineering. “Re: Request Update of ER Table 1.6-a.” E-mail (February 1) from B. 

30 Schiffer to J. Moore, Project Manager, Office of Federal and State Materials and Environmental 

31 Management Programs, U.S. Nuclear Regulatory Commission. Sheridan, Wyoming: WWC 

32 Engineering. 2013. ADAMS Accession No. ML13035A012. 

DRAFT Affected Environment

3-1

1 3 DESCRIPTION OF AFFECTED ENVIRONMENT

2

3 3.1 Introduction

4

5 The Ross Project would be located in northeastern Wyoming, in a rural area of western Crook 

6 County, approximately 35 km [22 mi] north of the town of Moorcroft, Wyoming (see Figure 2.1 in 

7 SEIS Section 2). This section describes the existing conditions at the Ross Project area, the 

8 697-ha [1,721-ac] area that is addressed in this Supplemental Environmental Impact Statement 

9 (SEIS), and its vicinity. The resource areas described in this section include land use; 

10 transportation; geology and soils; water, both surface water and ground water; ecology; noise; 

11 meteorology, climatology, and air quality; historical and cultural resources; visual and scenic 

12 resources; socioeconomics; public and occupational health and safety; and waste management. 

13 This description of the affected environment is based upon information provided in the 

14 Applicant’s license application and its Responses to the U.S. Nuclear Regulatory Commission’s 

15 (NRC’s) Requests for Additional Information (RAIs) and supplemented by additional information 

16 identified by NRC and others in the public domain (Strata, 2011a; Strata, 2011b; Strata, 2012a; 

17 Strata, 2012b). The information in this section forms the basis for the evaluation discussed in 

18 Section 4, Environmental Impacts and Mitigation Measures, which discusses the potential 

19 impacts of the Proposed Action and of each of the Alternatives in each resource area, as 

20 defined in SEIS Section 2.1.

21

22 3.1.1 Relationship between the Proposed Project and the GEIS 

23

24 As shown on Figure 2.3 in SEIS Section 2.1.1, the Ross Project area is located in the northern 

25 end and on the western edge of the Nebraska-South Dakota-Wyoming Uranium Milling Region

26 (NSDWUMR), as defined in the GEIS (NRC, 2009b). However, in defining the NSDWUMR, the 

27 Generic Environmental Impact Statement (GEIS) focused on potential in situ recovery (ISR) 

28 sites located in the Black Hills area of South Dakota, which is east of the Ross Project area. As 

29 a result, some of the affected environment discussion in the GEIS for the NSDWUMR does not 

30 reflect actual site conditions at the Ross Project area (in particular, the subsurface geology and 

31 water resources information). However, the GEIS’s discussion of the Wyoming East Uranium 

32 Milling Region (WEUMR), located west of the Ross Site, does provide germane information with 

33 respect to the Ross Project area’s subsurface geology and water resources. These differences 

34 are described in the subsequent sections below.

35

36 3.2 Land Use

37

38 The Ross Project area encompasses approximately 697 ha [1,721 ac], as described in SEIS 

39 Section 2.1.1. Nearby towns include Pine Haven, 27 km [17 mi] southeast; Moorcroft, 35 km

40 [22 mi] south; Sundance, 48 km [30 mi] southeast; and Gillette, 53 km [33 mi] southwest. The 

41 Ross Project area is adjacent to the unincorporated ranching community of Oshoto. There are 

42 11 residences within 3 km [2 mi] of the Ross Project, but no residences within the Project area. 

43 The closest residence is approximately 210 m [690 ft] north-northeast of the Ross Project 

44 boundary (see Figure 3.1). Existing land uses include livestock grazing, oil production, crop 

45 agriculture, communication and power transmission infrastructure, transportation infrastructure, 
DRAFT Affected Environment

3-2

1

Figure 3.1

Current Land Use of Ross Project Area

Source: Strata, 2012a.
DRAFT Affected Environment

3-3

1 limited recreational opportunities, stock and other reservoirs, and wildlife habitat (see Figure 

2 3.2). The actual land ownership of the Ross Project area’s surface differs from general land 

3 ownership in the region, in that 97.6 percent is owned by private landowners or the State of 

4 Wyoming, and 2.3 percent is owned by the Federal Government (as described in Section 3.3.1 

5 of the GEIS, 53.3 percent of Wyoming land is public land). The proposed Ross Project facility 

6 would be located on private property, and the wellfields would be located on private, State, and 

7 Federal lands.

8

9 The State of Wyoming owns all of the mineral rights below State-owned land, and the Federal 

10 Government controls all of the mineral rights below U.S. Bureau of Land Management (BLM)-

11 owned land. There are private lands where the Federal Government (through the BLM) controls 

12 the mineral rights below the Ross Project area, a situation known as a “split estate.” Between 

13 land ownership and split estate, the Federal Government through the BLM therefore controls 

14 11.7 percent of the total mineral rights under the Ross Project area (see Table 3.1), as opposed 

15 to 2.3 percent of the surface. All of the Federal rights are managed by the BLM. 

16

Table 3.1

Distribution of Surface Ownership and Subsurface Mineral Ownership

Ownership Surface Ownership Subsurface Mineral Ownership

Ha / Ac Percent Ha / Ac Percent

Private 553.3 / 1367.2 79.4 488.2 / 1206.4 70.1

State 127.1 / 314.1 18.2 127.1 / 314.1 18.2

Federal 16.2 / 40.0 2.3 81.3 / 200.9 11.7

TOTAL 696.6 / 1721.3 -- 696.6 / 1721.3 --

17 Source: Strata, 2011a.

18

19 3.2.1 Pasture-, Range-, and Croplands

20

21 Approximately 95 percent of the Ross Project area is used for rangeland, cropland, or 

22 pastureland. The largest portion, over 80 percent, is rangeland, while 14 percent is used for 

23 agriculture. In Crook County, rangeland is primarily used for cattle, with some grazing of sheep. 

24 Crops grown in the vicinity include hay, oats, and wheat.

25

26 3.2.2 Hunting and Recreation

27

28 There are many hunting and recreational opportunities within Crook County. However, there 

29 are limited opportunities for hunting and recreation within the Ross Project area because the 

30 majority of the land is privately owned. The State-owned land within the Ross Project area is 

31 accessible from County Road (CR) 193, but the Federal BLM land is not served by public roads 

32 so the public cannot access the BLM land to hunt. Large-game hunting in the area includes 

33 antelope (North Black Hills herd), mule deer (Powder River and Black Hills herds), and white34 tailed deer (Black Hills herd). Other hunting opportunities in the vicinity include sage-grouse, 

35 wild turkeys, and small game such as cottontail rabbits and snowshoe hares as well as red, 

36 gray, and fox squirrels. There are hunting seasons specific to each type of game; however, 
DRAFT Affected Environment

3-4

1 because of the predominantly private ownership of the land, hunting within the Ross Project 

2 area is limited. 

3

4 Recreational areas in the Ross Project vicinity include Devils Tower National Monument (Devils 

5 Tower), Black Hills National Forest, and Keyhole State Park. These areas offer access to 

6 hiking, camping, boating, biking, horseback riding, fishing, and hunting. The nearest of these is 

7 Devils Tower, approximately 16 km [10 mi] east of the Ross Project.

8

9 Although native fish have been observed in the Oshoto Reservoir, there are no fisheries in the 

10 Ross Project area because of the ephemeral or intermittent nature of the streams. The Oshoto 

11 Reservoir is partially located on State land; however, the Wyoming Game and Fish Department 

12 (WGFD) does not stock the Reservoir and it is not managed by any private agencies. However, 

13 fishing has been reported downstream of the Little Missouri River, outside of the Ross Project 

14 area (Strata, 2011a). 

15

16 3.2.3 Minerals and Energy

17

18 There are three operating oil wells within the Ross Project area, producing from depths between 

19 1,800 – 2,000 m [5,900 – 6,500 ft] below ground surface (bgs) (see Figure 3.2). Oil production 

20 is currently the only mineral extraction activity within the Ross Project area, although Crook 

21 County has other mineral resources which include coal, gas, bentonite (mine located 8 km [5 mi] 

22 to the northeast), sand, gravel, gypsum, and limestone in addition to uranium and vanadium. 

23

24 There are currently no licensed or operating uranium-recovery facilities within 80 km [50 mi] of 

25 the proposed Ross Project, although four potential projects are under preliminary consideration 

26 and are in the very early planning stages (Strata, 2011a). These include the Bayswater 

27 Uranium Corporation’s (Bayswater’s) Elkhorn, Wyoming, project approximately 27 km [17 mi] to 

28 the northeast of the Ross Project area; Bayswater’s Alzada, Montana, project at 58 km [36 mi] 

29 to the north-northeast; the UR-Energy/Bayswater’s Hauber, Wyoming, project at 21 km [13 mi] 

30 to the north-northeast; and Powertech Uranium Corporation’s (Powertech) Aladdin project at 64 

31 km [40 mi] to the east-northeast (see Figure 3.3). 

32

33 3.3 Transportation

34

35 The Proposed Action would rely on existing roads for supply and material transport, workforce 

36 commuting, and yellowcake and waste shipments to and from the Ross Project. The existing 

37 transportation network is discussed in this section; Figure 3.4 depicts this network. The primary 

38 access road to the Ross Project area is from Exit 153 on I-90. From that point the Ross Project 

39 is reached by a vehicle’s travelling south on US 14/16, west on WY 51, north on Bertha Road, 

40 north on CR 68 (also known as D Road), and north on CR 164 (also known as New Haven 

41 Road). The distance from the I-90 exit to D Road is 2.6 km [1.6 mi]. D Road is a two-lane 

42 asphalt and gravel road approximately 9 – 11 m [30 – 35 ft] wide with posted speed limits of 89 

43 km/hr [55 mi/hr] for cars and 72 km/hr [45 mi/hr] for trucks. The asphalt pavement extends to 

44 4.8 km [3 mi] north of Bertha Road, where it changes to a reclaimed-asphalt pavement, which 

45 has been rotomilled and blended with crushed base and subgrade. This surface continues for 

46 11.7 km [7.3 mi] after which D Road has only a gravel surface. New Haven Road is a two-lane, 

47 crushed-shale road approximately 7.6 – 9.1 m [25 – 30 ft] wide, with a posted speed limit of 72 

48 km/hr [45 mi/hr]. CR 193, also known as the Oshoto Connection, is a two-lane, crushed-shale 
DRAFT Affected Environment

3-5

1

Figure 3.2

Oil and Gas Wells within Two Miles of Ross Project Area

Source: WOGCC, 2010, as shown in Strata, 2012a.
3-6

1

Figure 3.3

Existing and Planned Uranium-Recovery Facilities

Sources: Bayswater, 2010a; NRC, 2009b; NRC, 2010a; NRC, 2010b; 

Powertech, 2010; and UR-Energy, 2010 as shown in Strata, 2012a.
3-7

1

Figure 3.4

Existing Transportation Network in Northeast Wyoming

Source: Strata, 2012a.
DRAFT Affected Environment

3-8

1 road that connects New Haven Road to D Road along the northern portion of the Ross Project 

2 area. Other county roads in the local vicinity that can be used to access the Ross Project area 

3 include CR 26 (Cow Creek Road), CR 91 (Spring Creek Road), and CR 211 (Deadman Road). 

4 Figure 2.1 shows the relative locations of these roads. Crook County conducts year-round 

5 routine maintenance of all CRs, including snow and debris removal, blading and grading, and 

6 miscellaneous repair. 

7

8 The Applicant has completed traffic studies on the county roads near the Ross Project area 

9 (Strata, 2011a), as has the State of Wyoming for its highways (see Table 3.2). Much of the 

10 existing truck traffic on the CRs adjacent to the Ross Project is due to local oil- and gas11 recovery activities as well as to a bentonite mine approximately 8 km [5 mi] northeast of the 

12 Project. 

13

Table 3.2

Traffic Volumes on Roads and Highways in Vicinity

of Ross Project Area

(2010)

Road/Highway Vehicles per Day

All Vehicles Trucks

I-90 at Moorcroft 4,744 906

New Haven Road 

South of Ross Project Area 108 10.8

New Haven Road 

South of Oshoto Connection 138 11

On-Site Measurements 

D Road

South of Deadman Road 25 1.5

D Road

North of Deadman Road 49 2.3

D Road

North of Oshoto Connection 62 6.2

Oshoto Connection 

between D Road and 

New Haven Road

87 11.3

14 Sources: Strata, 2011a, and Wyoming Department of Transportation (WYDOT), 2011.

15

16 3.4 Geology and Soils

17

18 The Lance District, which includes the Ross Project area (refer to Figure 2.1), is structurally 

19 situated between two major tectonic features: the Black Hills uplift to the east and the Powder 

20 River Basin to the west (Strata, 2011a). Both of these regional features are described in the 

21 GEIS (NRC, 2009b). The Black Hills uplift is generally allocated to the NSDWUMR, and the

22 Powder River Basin to the WEUMR. The Project area’s structural geology, stratigraphy, 

23 uranium mineralization, and seismology as well as the types and characteristics of the soils 

24 present at the Project area are described in this section. 
DRAFT Affected Environment

3-9

1 3.4.1 Ross Project Geology

2

3 The uranium-bearing units targeted for recovery within the Ross Project area are located in 

4 permeable sandstones of the Late Cretaceous Lance and Fox Hills Formations. The uranium 

5 roll fronts deposited in the Oshoto area demonstrate patterns similar to those across the Powder 

6 River Basin. The Ross Project area’s roll fronts were created by precipitation of uranium from 

7 ground water as a coating on sand grains primarily due to changes in aquifer conditions and 

8 ground-water flow (Buswell, 1982). The roll-front geometry at the Project area can vary as a 

9 result of differences of the host sandstones. The deeper Fox Hills roll fronts are generally 

10 thicker and more massive due to the near-shore environment into which the sediments were 

11 deposited. The lower Lance Formation sandstones were deposited in a fluvial environment (i.e., 

12 deposited by rivers or streams), resulting in narrower, often stacked channel systems containing 

13 uranium mineralization. Because of the variability of the depositional environment, the roll fronts 

14 near or at the Ross Project area are complex, and new exploration activities consistently yield 

15 increasing total uranium estimates. At this time, estimates of recoverable uranium within the 

16 Ross Project area exceed 2,495 t [5.5 million lb] of uranium and, based on current projections, 

17 these estimates are likely to increase as more exploration and characterization results become 

18 available. 

19

20 3.4.1.1 Structural Geology

21

22 The Black Hills uplift is a broad north-trending dome-like structure approximately 290 km [180 

23 mi] long (north to south) and 121 km [75 mi] wide (west to east) whose core is composed of 

24 Precambrian basement rocks (NRC, 2009b). The western flank of the uplift is characterized by 

25 a monoclinal (a one-limbed or step-like flexure) break near the Ross Project area (Lisenbee, 

26 1988). The eastern edge of the Ross Project area lies along the hinge of the Black Hills 

27 monocline. Because of the Black Hills monocline, the regional stratigraphic dip goes from 

28 essentially horizontal within the Powder River Basin, to steeply dipping along the eastern edge 

29 of the Ross Project area (see Figure 3.5). As indicated in the bedrock geologic map, Figure 3.6, 

30 the entire Ross Project area lies within the outcrop of the Lance Formation. The Cretaceous 

31 Formations below the Lance Formation all outcrop within roughly 3 km [2 mi] east of the Ross 

32 Project area.

33

34 Devils Tower, which is discussed later in the visual and scenic resources section of this section

35 (Section 3.10), is located approximately 16 km [10 mi] east of the Ross Project area. Devils 

36 Tower and the Missouri Buttes (15 km [9.5 mi] northeast of the Ross Project) are geologic 

37 features formed by the intrusion of igneous material (i.e., magma) through the earth’s crust 

38 during the Tertiary Period (i.e., subsequent to the deposition of the upper Cretaceous formations 

39 hosting the Lance District’s uranium deposits) (Robinson, 1964). 

40

41 With the exception of the Black Hills monocline, there are no significant structural features within

42 the Ross Project area. No faults of major displacement are known to exist within the Ross 

43 Project area; however, minor localized slumps, folds, and differential compaction features that 

44 formed shortly after deposition are common (Strata, 2011a).
3-10

 1

Figure 3.5

Generalized Cross Section of Black Hills Monocline in the Oshoto Area

Source: Strata, 2012a.
3-11

1

Figure 3.6

Surface Geology of Ross Project Area

Source: Strata, 2012a.
DRAFT Affected Environment

3-12

1 3.4.1.2 Stratigraphy

2

3 Stratigraphy describes the layers of rocks and soils below the ground’s surface (i.e., the 

4 subsurface) that host the ore zone as well as the layers of rock that separate the ore zone from 

5 the aquifers above and below it. An analysis of the local stratigraphy is used in assessments of 

6 whether the ore zone is adequately confined above and below by rock layers of low permeability 

7 that would prevent vertical movement of water from the ore zone.

8

9 The regional stratigraphy of the Black Hills area is shown in Figure 3.7. The ore zone, which 

10 would be the “production zone” (i.e., the deposits from which uranium would be recovered) at 

11 the Ross Project, is within the upper Cretaceous stratigraphic units, including the lower Lance 

12 (Hell Creek) and upper Fox Hills Formations. 

13

14 Detailed analysis of the subsurface stratigraphy and mineralogy of the Ross Project area began 

15 with the first uranium exploration and development efforts in the Oshoto area during the 1970s 

16 by the Nubeth Joint Venture (Nubeth) as described in SEIS Section 2.1.1 (Strata, 2011a). In 

17 2008 and 2009, the Applicant began confirmation and exploration drilling at the Ross Project 

18 (Strata, 2011a). As of October 2010, the Applicant possessed information from the 1,682 holes 

19 drilled by Nubeth as well as its own 540 recent exploration drillholes, which are all located within 

20 a 0.8-km [0.5-mi] radius of the Ross Project area. The logs of these drillholes were used by the 

21 Applicant to characterize the site-specific stratigraphy of the Ross Project area (Strata, 2011a; 

22 Strata, 2011b).

23

24 The Pierre Shale in this area is a massively bedded, relatively uniform, thick marine shale that is 

25 considered a regional confining layer (or “unit” or “interval”) (NRC, 2009b). This unit outcrops 

26 approximately 0.4 km [0.3 mi] east of the Ross Project’s eastern boundary (see Figure 3.6). 

27 Based upon the width of the outcrop and geophysical logs from oil wells located in the general 

28 area, the Applicant has estimated the thickness of the Pierre Shale to be approximately 670 m 

29 [2,200 ft] thick under the Ross Project area (Strata, 2011a; Robinson, 1964). Because of its 

30 thickness and low permeability, the Pierre Shale is considered the lower ground-water-confining 

31 unit within the Ross Project vicinity, separating the older, deeper Formations below the Pierre 

32 Shale from the Ross Project’s target ore zones which are in the overlying Fox Hills and Lance 

33 Formations. 

34

35 Below the Pierre Shale, the Cambrian-age Deadwood and Flathead Formations are 

36 encountered at depths of approximately 2,490 – 2,600 m [8,160 – 8,560 ft] bgs (WDEQ/WQD, 

37 2011). The Applicant proposes that these Formations are the optimum target interval for the 

38 Underground Injection Control (UIC) Class I deep-injection wells that would be used for waste39 water disposal at the Ross Project. The Applicant has already received its UIC Class I Permit 

40 for this type of disposal (Strata, 2011a).

41

42 The Fox Hills Formation, which lies between the Pierre Shale and the Lance Formation, 

43 outcrops along the proposed eastern boundary of the Ross Project (refer to Figure 3.6). The 

44 Fox Hills Formation is a sequence of marginal marine to estuarine sand deposits that were 

45 deposited during the eastward regression of the upper Cretaceous interior seaway (Dunlap, 

46 1958; Merewether, 1996). In the vicinity of Oshoto, the Fox Hills Formation is divided into lower 

47 and upper units, which are based on differences in color, bedding, trace fossil concentrations, 

48 lithology, and texture (Dodge and Spencer, 1977). 
DRAFT Affected Environment

3-13

1

2

Figure 3.7

Regional Stratigraphic Column of Area Containing the Lance District

Source: South Dakota School of Mines, 1963.
DRAFT Affected Environment

3-14

1 Above the Fox Hills Formation, the Lance Formation has been interpreted as being fluvio-deltaic 

2 in origin, consisting of a mixture of non-marine-deposited sandstones and floodplain mudstones 

3 with thin beds of coal (Connor, 1992). This depositional environment created a stratigraphic 

4 sequence of shale, mudstones, and sandstones that is complicated and vertically 

5 heterogeneous (Dodge and Powell, 1975). 

6

7 The horizontal continuity of the various stratigraphic intervals beneath the Ross Project is clearly 

8 depicted on the geologic cross-sections and fence diagrams provided by the Applicant (Strata, 

9 2011a; Strata, 2012b). The upper Fox Hills and lower Lance Formations are stratigraphically 

10 continuous and hydraulically isolated from the overlying upper Lance Formation by continuous 

11 and impermeable mudstones and claystones as well as from the underlying units by the basal 

12 Fox Hills siltstone-claystone interval and the Pierre Shale.

13

14 3.4.2 Soils 

15

16 Soils at the Ross Project are typical for semi-arid grass- and shrublands in the western U.S. 

17 (Strata, 2011a). Most of these soils are classified as Aridic Argiustolls, Ustic Haplargids, or 

18 Ustic Torrifluvents that were derived from the Lance Formation over time.

19

20 General topography of the Ross Project area ranges from nearly level uplands to steep hills, 

21 ridges, and breaks. The soils occurring on hills, ridges, and breaks at the Ross Project are 

22 generally sandy or coarse texture with clayey or fine-textured soils occurring on nearly level 

23 uplands and near drainages. The Ross Project area contains moderate and deep soils on level 

24 upland areas and drainages with shallow soils located on hills, ridges, and breaks. Figure 3.8

25 depicts the types of pre-licensing baseline soils located on the Ross Project area (Strata, 2011a; 

26 Strata, 2012b). The area of the Ross Project is about equally divided between sandy loam soils 

27 and clay loam soils (Strata, 2011a; Table 2.6-9 in Strata, 2012b). The soil characteristics of 

28 both the Proposed Action’s south site (Alternative 1) and the north site (Alternative 3) are of 

29 particular interest since these would be the largest areas of soils disturbance during the Ross 

30 Project (see Table 3.3).

31

32 Approximate topsoil salvage depths range from 0.13 – 1.5 m [0.42 – 5 ft] with an average of 0.5 

33 m [1.7 ft]. Factors that affect the suitability of a soil as a vegetation-growth medium are: texture, 

34 soil-adsorption ratio (SAR), electrical conductivity (EC), and pH as well as selenium and calcium 

35 carbonate concentrations. Based upon a comparison of laboratory analysis results and field 

36 observations with the respective Wyoming Department of Environmental Quality (WDEQ)/Land 

37 Quality Division (LQD) standards, suitable and marginally suitable material was found in 19 of 

38 the 26 samples within the Ross Project area (Strata, 2011a; WDEQ/LQD, 1994); unsuitable 

39 material was found in 7 of the 26 samples. The parameters that exceeded topsoil suitability 

40 criteria in those seven samples were high clay texture, high SAR, alkaline pH, and high 

41 concentration of selenium. 

42

43 The hazard for wind and water erosion at the Ross Project varies from negligible to severe, 

44 based upon the soil-mapping descriptions. The potential for wind and water erosion is primarily 

45 dependent on the surface characteristics of the soils, including texture and organic-matter 

46 content. Given the slightly coarser texture of the surface horizons at the majority of the Ross 

47 Project, the soils are slightly more susceptible to erosion from wind than water.
DRAFT Affected Environment

3-15

1

Table 3.3 

Soil Coverage and Characteristics for Ross Project Area

Soil Name

Soil 

Map 

Symbol

Alternative 1

(South)

Site

(ha [ac])

Alternative 3 

(North)

Site

(ha [ac])

Water 

Erosion 

Hazard

Wind 

Erosion 

Hazard

Absted very fine 

sandy loam AB 3.7 [9.1] N/A Moderate Moderate

Bidman loam BI 9.3 [23.1] 2.2 [5.4] Moderate Moderate

Cushman very fine 

sandy loam CU N/A 2.0 [5.0] Moderate Slight

Forkwood loam FO 7.1 [17.5] 3.4 [8.4] Moderate Slight

Nunn clay loam NU N/A 2.4 [5.9] Slight Slight

Shingle clay loam SH N/A 2.3 [5.7] Moderate Moderate

Tassel fine

sandy loam TA N/A 2.7 [6.7] Slight Moderate

2 Source: Strata, 2011a.

3 Notes:

4 N/A = The type of soil is not present at the south or north site as indicated.

5 “Water Erosion Hazard” describes the susceptibility of the soil type to erosion by water, and 

6 “Wind Erosion Hazard” describes the susceptibility of the soil type to erosion by wind.

7

8 Although laboratory analyses for non-radioactive, chemical constituents in the soils at the Ross 

9 Project are not required by WDEQ/LQD to establish pre-operational baseline values, radioactive 

10 constituents in some soils were measured in order to establish such a pre-licensing baseline for 

11 radioactive species concentrations. These concentrations of specific radioactive elements are 

12 presented in Table 3.21 (see Section 3.12.1). 

13
DRAFT Affected Environment

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1

Figure 3.8

Soil Mapped Units at Ross Project Area

Source: Strata, 2012a.
DRAFT Affected Environment

3-17

What are the characteristics of uranium deposits 

that make them amenable to in situ uranium 

recovery?

Certain geologic and hydrological features make a 

uranium deposit in an ore zone suitable for in situ 

uranium recovery (based on Holen and Hatchell, 1986, 

as cited in NRC, 2009b):

■ Deposit geometry: For ISR operations, the

wellfield boundaries are defined based upon the 

geometry of the specific uranium mineralization. 

The deposit should generally be horizontal and 

have sufficient size and lateral continuity to enable 

economic uranium extraction.

■ Permeable host rock: The host rock of the orezone aquifer must be permeable enough to allow 

the solutions (the lixiviant) to access and interact 

with the uranium mineralization. Preferred flow 

pathways, such as fractures in the rock, may short 

circuit portions of the mineralization and reduce the 

recovery efficiency. The most common host rocks

are sandstones.

■ Confining layers: Hydrogeologic (formation) 

geometry must prevent lixiviant from vertically 

migrating. Typically, low permeability layers such 

as shales or clays “confine” the uranium-bearing 

sandstone(s) both above and below. This

confinement isolates the uranium-producing zone

from overlying and underlying aquifers.

■ Saturated conditions: For ISR uranium-recovery 

techniques to work, the uranium mineralization 

should be located in a hydrologically saturated zone

(in an aquifer). 

1 3.4.3 Uranium Mineralization

2

3 The process of uranium mineralization in 

4 the Lance District in general and 

5 specifically at the Ross Project is 

6 consistent with the characteristics of the 

7 uranium deposits that are identified in the 

8 GEIS as amenable to in situ uranium 

9 recovery. This mineralization includes 

10 fluvial sandstones (NRC, 2009b). 

11

12 The lithological variability within the 

13 upper Fox Hills and Lance Formations 

14 would allow the geometric definition of 

15 ore deposits (i.e., areas of uranium 

16 mineralization) with sufficient size and 

17 continuity to make economic recovery 

18 viable. The saturated sandstone 

19 lithology of the ore zone would provide 

20 adequate permeability to allow uranium21 recovery solutions access and interaction 

22 with uranium in the ore zone. In addition, 

23 the presence of impermeable intervals 

24 above and below the ore zone would 

25 prevent vertical migration of lixiviant or 

26 other fluids. Thus, the geology of the 

27 deposits would provide the 

28 characteristics required for an effective 

29 uranium-extraction project. 

30

31 The mineralogy and petrography 

32 determined by the Applicant indicated 

33 that the ore zone is suitable for ISR

34 (Strata, 2011a). The sandstone in the ore zone consists of 60 percent quartz, 35 percent 

35 feldspar, 5 percent montmorillonite clay, approximately 1 percent organic material, and less than 

36 1 percent of pyrite and carbonate minerals (Strata, 2011a). The presence of pyrite confirms the 

37 geochemical conditions necessary for formation of the roll front. Petrographic analyses show 

38 that the ore zone has sufficient porosity (or reservoir quality) for movement of lixiviant from 

39 injection to recovery wells (Strata, 2011a). The ore zone is composed of fine grained, 

40 moderately well sorted, argillaceous sandstone with subangular to subrounded grains that are 

41 lightly to moderately compacted. 

42

43 Consistent with the GEIS and typical of roll-front deposits (NRC, 2009b), analysis of the 

44 samples from the ore zone at the Ross Project shows that the principal uranium minerals are 

45 uraninite, an uranium oxide (UO2), and coffinite, an uranium silicate (U[SiO4][OH])4) (Strata, 

46 2011a). Vanadium in the form of vanadinite (a lead chlorovanadate [Pb5{VO4}3Cl]) and carnotite 

47 [a hydrated potassium uranyl vanadate (K2[UO2]2[VO4]2 3H2O)] is also found in association with 

48 the uranium at an average ratio of 0.6 (vanadium) to 1.0 (uranium).
DRAFT Affected Environment

3-18

1 3.4.4 Seismology

2

3 There are no active faults with surface expression mapped within or near the Ross Project, 

4 according to the U.S. Geological Survey (USGS) (USGS, 2011). The closest capable faults to 

5 the Project area are located in central Wyoming, 270 km [170 mi] to the west-southwest. Six 

6 east-west trending structural faults through the Ross Project area were mapped by Buswell 

7 (1982). These faults are due to heterogeneity of the lithology among the shale and sandstone 

8 intervals within the upper Cretaceous Formations. However, these were based upon limited 

9 observations and information from one core sample and one aquifer test. The Applicant’s 

10 examination of multiple geological cross-sections developed from stratigraphic information 

11 obtained from exploration drillholes do not appear to support this interpretation of the Ross 

12 Project area’s faults (see SEIS Section 3.4.1.2) (Strata, 2011a). 

13

14 Two earthquakes with magnitudes greater than 2.5 (on the Richter Magnitude Scale) have been 

15 recorded in Crook County and nine in Campbell County (Strata, 2011a). Of those with 

16 magnitudes greater than 2.5, 3 had magnitudes 3.0 and greater (Case, Toner, and Kirkwood, 

17 2002). The first reported earthquake in Crook County with a magnitude of greater than 3 

18 occurred near Sundance on February 3, 1897, severely shaking the Shober School on Little 

19 Houston Creek southwest of Sundance. On November 2004, an earthquake of magnitude of 

20 3.7 was recorded near Moorcroft in Crook County. On February 18, 1972, a magnitude 4.3 

21 earthquake occurred approximately 30 km [18 mi] east of Gillette near the Crook-Campbell 

22 County line (Case, Toner, and Kirkwood, 2002). No damage was reported. The occurrence of 

23 few, low-magnitude events is consistent with the predicted low probability of seismic-induced or 

24 earthquake-caused ground motion in northeastern Wyoming (Algermissen et al., 1982).

25

26 Earthquakes generally do not result in ground-surface rupture unless the magnitude of the event 

27 is greater than 6.5 (Case and Green, 2000). Because of this, areas of Wyoming that do not 

28 have active faults exposed at the surface, such as the Ross Project area, are generally thought 

29 not to be capable of having earthquakes with magnitudes over 6.5. As shown on Figure 3.9, the 

30 probability of an earthquake with magnitude greater than or equal to 6.5 in the vicinity of the 

31 Ross Project is less than 0.001. This figure was prepared using the USGS Probabilistic Seismic 

32 Hazard Analysis (PSHA) model (USGS, 2010). Earthquakes with magnitudes less than 6.5 

33 would cause little damage in specially built structures, but they could cause considerable 

34 damage to ordinary buildings and even severe damage to poorly built structures. Some walls 

35 could collapse, but underground pipes would generally not be broken, and ground cracking 

36 would not occur or would be minor (USGS, 2010).

37

38 3.5 Water Resources

39

40 Water resources in the vicinity of Ross Project include both surface water and ground water. 

41 Both the quantity and the quality of both surface and ground waters are described in this 

42 section.

43

44 Pre-licensing baseline water-quality data have been collected and analyzed by the Applicant in 

45 accordance with the following guidelines:
DRAFT Affected Environment

3-19

1

Figure 3.9

Probability of Earthquake with Magnitude of

Greater Than or Equal to 6.5 in 50 Years

Source: Strata, 2011a.

Note: Darkest shaded area indicates probability between 0.003 and 0.002; 

lighter shaded area indicates probability between 0.002 and 0.001; lightest 

shaded area indicates probability between 0.001 and 0.000.

Ross Project area
DRAFT Affected Environment

3-20

1 ■ American Society for Testing and Materials (ASTM) International’s Standard D449-85a, 

2 Standard Guide for Sampling Groundwater Monitoring Wells, as recommended in the NRC’s 

3 guidance document, NUREG–1569, Standard Review Plan for In Situ Leach Uranium 

4 Extraction License Applications (NRC, 2003). This ASTM Standard was replaced by ASTM 

5 Standard D4448-01 in 2007.

6 ■ WDEQ’s “Hydrology, Coal and Non Coal,” Guideline No. 8 (WDEQ/LQD, 2005b). 

7 ■ NRC’s Regulatory Guide 4.14, Radiological Effluent and Environmental Monitoring at 

8 Uranium Mills, Revision 1 (NRC, 1980).

9

10 These guidance documents by both NRC and WDEQ recommend water samples be filtered 

11 before the analysis of any metals each sample might contain. ASTM D449-85a (now ASTM 

12 4448-01) and the NRC’s Regulatory Guide 4.14 also specify analysis of radiological parameters 

13 in filtered samples (NRC, 1980). The results of the analysis of constituents in filtered samples 

14 are then reported as “dissolved” concentrations (versus “unfiltered” samples, which are reported 

15 as “total” concentrations). The filtering of water samples before analysis for metals is consistent 

16 with WDEQ/WDQ’s Groundwater Sampling for Metals: Summary, which explains that filtering 

17 samples eliminates bias that may arise from variable turbidity in the samples (WDEQ/WQD, 

18 2005a). The NRC’s guidance on filtering samples applies to both pre-licensing baseline site19 characterization monitoring efforts as well as post-licensing, pre-operational and operational 

20 environmental monitoring efforts during ISR operation and aquifer restoration.

21

22 The standardized protocol for filtering samples that will be analyzed for metals also allows a 

23 sound comparison among other data sets. For example, pre- and post-ISR operation water24 quality data available for Nubeth also reported dissolved metal concentrations (i.e., filtered 

25 samples were analyzed). 

26

27 3.5.1 Surface Water

28

29 The Ross Project area is located in the upper reaches of the Little Missouri River Basin. The 

30 Little Missouri River originates in northeastern Wyoming, flows through southeastern Montana, 

31 through northwestern South Dakota, and into North Dakota where it empties into the Missouri 

32 River at Lake Sakakawea. The total river length is 652 km (405 mi), and the total drainage area 

33 (i.e., the area where all surface waters flow toward the Little Missouri River) is approximately 

24,500 km2 [9,470 mi2 34 ]. Figure 3.10 depicts the Little Missouri River Basin. The drainage area 

35 of the Little Missouri River at the downstream boundary of the Ross Project area is 

approximately 47 km2 [18.2 mi2 36 ].

37

38 A surface-water monitoring system has been employed by the Applicant to characterize surface39 water quantity and quality at the Ross Project area. This system includes three monitoring 

40 stations and was designed to monitor the major surface-water drainages to the Little Missouri 

41 River and to establish pre-licensing baseline, site-characterization surface-water quality.

42

43 Surface-Water Features

44

45 The surface-water features located within the Ross Project are depicted in Figure 3.11 and 

46 consist of several reservoirs and minor stream channels. Oshoto Reservoir, located in the 

47 channel of the Little Missouri River, is the main hydrologic feature of the Project area (Water 
DRAFT Affected Environment

3-21

1

Figure 3.10

Little Missouri River Basin and Surface-Water Gaging Stations

Source: Strata, 2012a.
DRAFT Affected Environment

3-22

1

Figure 3.11

Surface-Water Features of Ross Project Area

Source: Strata, 2012a.
DRAFT Affected Environment

3-23

1 Right Permit No. P6046R) (WSEO, 2006). The only potential springs identified within the Ross 

2 Project area are associated with nearby wetlands (see Section 3.5.2 of this SEIS) or with the 

3 Little Missouri River in the vicinity of the Oshoto Reservoir.

4

5 The Applicant has identified 12 existing reservoirs within or just outside the Ross Project area 

6 using aerial photography, Wyoming State Engineer’s Office (WSEO) permits, and landowner 

7 interviews (see Figure 3.11). Other than the Oshoto Reservoir, which has a maximum capacity 

8 of 21 ha-m [173 ac-ft] and an area of 11.3 ha [28 ac], all the identified reservoirs have a capacity 

9 of less than 1.2 ha-m [10 ac-ft] and a surface area of less than 1 ha [2.5 ac] (Strata, 2011a). 

10 The Oshoto Reservoir has the potential to affect stream flow and appears to influence water11 table elevations in its proximity (Strata, 2011a). 

12

13 There are three Wyoming Pollution Discharge Elimination System (WYPDES)-permitted outfalls

14 associated with the oil-production operations within the watershed that includes the Ross 

15 Project area: two upstream from the Ross Project (Permit Nos. WY0044296 and WY0033065) 

16 and one downstream (Permit No. WY0034592) (Strata, 2011a). Discharge rates from the 

outfalls are relatively low, approximately 0 – 150 m3

/d [0 – 5,300 ft3 17 /d].

18

19 Surface-Water Flow

20

21 As shown in Figure 3.10, five USGS gaging stations are located on the Little Missouri River 

22 downstream of the Ross Project (USGS, 2012a). The mean annual discharges range from 2 

m3

/s [77 ft3/s] at the most upstream gaging station (near Alzada, Montana) to 15.1 m3 23 /s [533 

ft3 24 /s] at the most downstream gaging station (near Watford City, North Dakota). The discharges 

25 are typically lowest from November through January and highest during the months of March 

26 through June (Strata, 2011a). The peak flow for the Alzada, Montana, gaging station occurred 

in April 1944 when an estimated discharge of 170 m3

/s [6,000 ft3 27 /s] occurred. The peak flow at 

the Camp Crook, South Dakota, gaging station took place in March 1978 with a flow of 267 m3 28 /s 

[9,420 ft3 29 /s]. The timing of these events indicates that snow melt and spring runoff typically 

30 result in the highest flows for this portion of the Little Missouri River.

31

32 The Applicant has established three surface-water monitoring stations and installed continuous 

33 stage recorders and pump samplers at each station within the Ross Project area in 2010 (see 

34 Figure 3.12) (Strata, 2011a). The stations were located at two sites on the Little Missouri River 

35 and one site on Deadman Creek, a tributary to Little Missouri River. The stage recorders are 

36 designed to continuously measure discharge and are integrated with the pump samplers that 

37 collect water-quality samples during runoff events. The Applicant reports flow data from the 

38 three surface-water monitoring stations from June 15, 2010, to October 11, 2011, with a break 

39 during the respective winter when the monitoring stations were removed to prevent their 

40 freezing (Strata, 2012a).

41

42 The results of the surface-water monitoring indicate that, where the streams enter the Ross 

43 Project area (SW-2 and SW-3), flow is in response to only snow-melt or precipitation events 

44 (i.e., ephemeral) (Strata, 2011a). The Little Missouri River, downstream from the proposed 

45 Ross Project boundary (SW-1), has flow for an extended period of the year but not all of the 
DRAFT Affected Environment

3-24

1

Figure 3.12

Surface-Water Monitoring Stations at Ross Project Area

Source: Strata, 2012a.
DRAFT Affected Environment

3-25

1 year and is, thus,

2 intermittent. The Applicant

3 compared the average daily 

4 flow observed at SW-1 to the 

5 water-surface elevation in 

6 Oshoto Reservoir (Strata, 

7 2011a); the comparison 

8 suggests a correlation 

9 between the increased flow 

10 in the Little Missouri River 

11 downstream of Oshoto 

12 Reservoir and the amount of 

13 head in the Reservoir. This 

14 would indicate that some of 

15 the flow could be attributed to 

16 the stored capacity in Oshoto Reservoir. 

17

18 All streams within the Ross Project area, including the Little Missouri River and Deadman 

19 Creek, are classified by WDEQ/Water Quality Division (WQD) as 3B streams (WDEQ/WQD, 

20 2001). A Class 3B stream is defined by the WDEQ/WQD as an intermittent or ephemeral 

21 stream with a designated use of “aquatic life other than fish.” Uses such as drinking water and 

22 fisheries are excluded in a Class 3B stream. Approximately 64 km [40 mi] downstream of the 

23 Ross Project, the Little Missouri River becomes a class 2ABWW stream at its confluence with 

24 Government Canyon Creek; at this point, the River becomes protected as a drinking water 

25 source (2AB) and warm-water (WW) fishery. 

26

27 There are no long-term stream-flow records for flows within or adjacent to the Ross Project; 

28 therefore, an U.S. Army Corps of Engineers’ (USACE) Hydrologic Engineering Center (HEC)-

29 hydrologic modeling system (HMS) model was developed by the Applicant to estimate the 

30 peaks and volumes of floods for various recurrence intervals (Strata, 2011a). The resulting 

31 inundation boundaries are shown on Figure 3.13. Measured peak flows during a 2-year, 24-

32 hour storm event in May 2011 were less than predicted by the model, suggesting that the 

33 predicted model flows are conservatively high (Strata, 2012a). 

34

35 Surface-Water Quality 

36

37 Data from water-quality analyses of samples obtained from the Ross Project surface-water 

38 monitoring stations in 2009 and 2010 are provided in the Applicant’s Environmental Report (ER) 

39 and Technical Report (TR) (see Figure 3.12) (Strata, 2011a; Strata, 2011b). Due to reasons 

40 ranging from the Applicant’s not having a landowner’s permission to no-flow conditions (i.e., 

41 there was no water flowing or the water was frozen), the number of quarters in which the 

42 monitoring stations were sampled ranges from one to six (Strata, 2011a). Water-quality 

43 analytical data from samples collected in 2011 were submitted to WDEQ/LQD and are provided 

44 in the Applicant’s Responses to the RAIs issued by the NRC (Strata, 2012a). The data from 

45 2011 are generally consistent with the 2009 and 2010 data, indicating a representative 

46 characterization of surface-water quality.

What are the types of streams at the Ross Project area?

Perennial Streams: A perennial stream is a stream or part of a stream 

that flows continually during all of the calendar year as a result of 

ground-water discharge or surface runoff.

Intermittent Streams: An intermittent stream is a stream or part of a 

stream where the channel bottom is above the local water table for 

some part of the year, but which is not a perennial stream.

Ephemeral Streams: An ephemeral stream is a stream which flows 

only in direct response to a single precipitation event in the immediate 

watershed or in response to a single snow-melt event, and which has a 

channel bottom that is always above the prevailing water table.
DRAFT Affected Environment

3-26

1

Figure 3.13

Predicted 100-Year Flood Inundation Boundaries

Source: Strata, 2012a.
DRAFT Affected Environment

3-27

1 The surface-water monitoring data characterizing the Little Missouri River and Deadman Creek 

2 from the first and second quarter of 2010 are summarized and described below. These data 

3 indicate that the overall water quality meets Wyoming’s surface-water criteria for a Class 3B 

4 stream, which is the designation for the Little Missouri River. 

5

6 ■ The water quality in all streams is generally consistent across the entire Ross Project area.

7 ■ The field pH measurements ranged from 7.6 – 8.9 standard units (s.u.), indicating alkaline 

8 water.

9 ■ The field measurements of dissolved oxygen ranged from 6.9 – 10.5 mg/L, indicating an 

10 intermediate to high level of oxygen in the water.

11 ■ Total salinity of the waters, expressed as total dissolved solids (TDS) concentrations, are 

12 low to moderate, ranging from 210 mg/L – 940 mg/L, and the water composition is 

13 dominated by sodium and bicarbonate. 

14 ■ Iron and manganese concentrations in unfiltered samples ranged from 0.32 – 0.95 mg/L and 

15 0.05 – 0.21 mg/L, respectively, suggesting the presence of suspended sediment in the 

16 samples.

17 ■ Dissolved metals were near or below detection limits, with the exception of iron and 

18 uranium. Iron concentrations ranged from less than 0.05 mg/L to 0.92 mg/L, with an outlier 

19 of 8.32 mg/L in the sample collected in the third quarter from Station R-5. Concentrations of 

20 dissolved uranium ranged from 0.003 – 0.02 mg/L.

21 ■ Dissolved radium-226 was less than the detection limit of 0.01 Bq/L [0.2 pCi/L]. Dissolved 

22 radium-228 was undetected (i.e., less than 0.04 Bq/L [1 pCi/L]) except for one sample 

23 obtained at Station SW2, where it was counted at 0.05 Bq/L [1.3 pCi/L]. 

24 ■ Gross alpha and gross beta ranged from 0.2 – 0.33 Bq/L [4 – 8.8 pCi/L) and 0. 2 – 0.41 Bq/L 

25 [6 – 11.2 pCi/L], respectively.

26

27 Other water-quality data suggest that the TDS increases downstream in the Little Missouri River 

28 and sulfate becomes the dominate anion (Langford, 1964). 

29

30 The total anion/cation balances were calculated from the analyses of major ions as a quality31 control check on the laboratory analyses. The balances, less than 3 percent in 31 of the 36 

32 samples analyzed, and between 3 and 5 percent in five samples, validated the accuracy of the 

33 analyses (Strata, 2011a). 

34

35 The Applicant attempted to collect water-quality samples from 11 reservoirs (see Figure 3.12) 

36 from the third quarter of 2009 through the third quarter of 2011 (i.e., quarterly) (Strata, 2011a; 

37 Strata, 2011b, Strata. 2012a). Samples were not collected when the reservoirs were dry or 

38 frozen or when the Applicant was not able to obtain the landowner’s permission. These water39 quality data indicate the following:

40

41 ■ Higher TDS corresponds to low-flow conditions in the fourth quarters of both years. TDS in 

42 samples of the reservoirs on the channels of the Little Missouri River and Deadman Creek, 

43 upstream from Oshoto Reservoir, ranged from 970 – 2,320 mg/L compared to a range of 

44 460 – 730 mg/L in the Oshoto Reservoir and a range of 100 – 170 mg/L in the reservoir on 
DRAFT Affected Environment

3-28

1 the Little Missouri River downstream of the Oshoto Reservoir. The TDS in the reservoirs 

2 upland from the stream channels range from 110 – 1190 mg/L. Bicarbonate or carbonate 

3 (depending upon the pH) was the dominant anion in all of the waters. Sodium was the 

4 dominant cation, except in waters on the low end of the TDS range, where calcium was 

5 often the dominant cation.

6 ■ The waters in all reservoirs were alkaline, with field pH measurements generally ranging 

7 from 8 – 10 s.u. 

8 ■ Field-measured dissolved oxygen ranged from 0.46 – 11.3 mg/L, suggesting seasonal low 

9 oxygen conditions. 

10 ■ Similar to the streams, dissolved metals were generally at or near the laboratory detection 

11 limits, except for uranium and iron. Uranium ranged from less than 0.001 – 0.009 mg/L in all 

12 of the reservoirs except for those on Deadman Creek, where uranium concentration ranged 

13 from 0.019 – 0.087 mg/L. Detectable concentrations of dissolved iron generally 

14 corresponded to depleted dissolved oxygen levels. Measureable concentrations of total iron 

15 and manganese indicate the presence of sediment in the samples.

16 ■ The available data for radionuclides show that most of the analyses were less than the

17 laboratory’s lower limit of detection. However, detectable concentrations of lead-210, 

18 radium-226 (dissolved and suspended), dissolved radium-228, and suspended thorium-230 

19 were detected. Gross alpha and gross beta ranged from less than 2 – 48.4 pCi/L and 3.9 –

20 48.5 pCi/L, respectively. The highest values of gross alpha and gross beta were measured 

21 in samples from reservoirs on Deadman Creek.

22

23 Surface-Water Uses

24

25 A search of the WSEO database of permitted surface-water rights within the Ross Project 

26 boundaries and the adjacent 3-km [2-mi] radius revealed that 43 surface-water rights existed 

27 within and adjacent to the Ross Project in 2010 (WSEO, 2006; Strata, 2011a). The search of 

28 the WSEO database indicated that nearly half of the water-right permits have been cancelled, 

29 while the remaining permits are complete, fully adjudicated, or un-adjudicated (Strata, 2011a). 

30 In addition to the permitted surface-water rights, there are at least 17 additional reservoirs within 

31 or adjacent to the Ross Project area, although none of these reservoirs was listed in the WSEO 

32 water-rights database, except for the Oshoto Reservoir (Strata, 2011a). 

33

34 Surface water within the Ross Project area and surrounding 3-km [2-mi] vicinity is primarily used 

35 for livestock watering, with lesser amounts used for irrigation and industrial uses (primarily as a 

36 temporary water supply for oil- and gas-construction activities) (Strata, 2011a). Including 

37 reservoirs not listed in the WSEO database, stock reservoirs account for approximately 90

38 percent of the total active water rights (Strata, 2011a). Most of the stock reservoirs were 

39 constructed before 1970, and the majority are still in use today. Irrigation-water rights only 

40 account for a relatively small portion (less than 10 percent) of the surface-water rights. All of the 

41 irrigation rights were permitted 50 – 100 years ago for relatively small areas (28 ha [70 ac] or 

42 less). The one water right for Nubeth signifies the rise of uranium exploration in the late 1970s. 

43 Following this, there were some 15 temporary water-haul permits for oil- and gas-related 

44 activities from 1980 – 1991. Finally, the two most recent water rights were appropriated by the 

45 Applicant for exploration activities at the Ross Project area (Strata, 2011a).
DRAFT Affected Environment

3-29

1 3.5.2 Wetlands

2

3 The Federal definition of wetlands includes “those areas that are inundated or saturated by 

4 surface or ground water at a frequency and duration sufficient to support, and that under normal 

5 circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil 

6 conditions. Wetlands generally include swamps, marshes, bogs, and similar areas” (33 CFR 

7 Part 328.3). Wetlands are important resources that provide habitat for aquatic fauna and flora, 

8 filter sediments and toxicants, and attenuate floodwaters. 

9

10 Projects that discharge, dredge, or fill material into “Waters of the United States,” a concept 

11 related to surface- and ground-water regulation which includes special aquatic sites and 

12 wetlands under the jurisdiction of the USACE, require accurate identification of wetland 

13 boundaries for Section 404 of the Clean Water Act-permitting process. Through the Section 

14 404 permitting process, the USACE can authorize dredge or fill activities by issuance of a 

15 standard individual permit, regional permit, or the Nationwide Permit (NWP). 

16

17 Site-specific field surveys on behalf of the Applicant were conducted at the Ross Project by 

18 WWC Engineering (WWC) staff on June 22 and 28 as well as July 8 and 21, 2010. These 

19 surveys were in accordance with the “Interim Regional Supplement to the USACE Wetlands 

20 Delineation Manual: Great Plains Region” (USACE, 2008; Strata, 2011a). These wetlands 

21 surveys were conducted to identify and to characterize the wetlands located within the Ross 

22 Project area. Existing data used in the survey included Natural Resource Conservation Service 

23 (NRCS) soil mapping, U.S. Fish and Wildlife Service’s (USFWS’s) National Wetlands Inventory 

24 (NWI) mapping, and aerial photography taken May 2010 (NRCS, 2010; USFWS, 2012a; Strata, 

25 2011a). 

26

27 Thirteen wetland sites were identified on the NWI maps within the Ross Project area and were 

28 investigated during the 2010 field surveys. Potential wetlands identified during the initial June 

29 survey were later visited during another survey in July to verify that wetland characteristics were 

30 present. The wetlands-survey results, photographs, and correspondence with the USACE are 

31 provided in the Applicant’s ER (Strata, 2011a). All but two of the NWI areas were included in 

32 the baseline field-delineated wetlands (Strata, 2011a). The two sites not included did not have 

33 the three required characteristics for a wetland. The three criteria are: 1) hydrophytic 

34 vegetation (i.e., plants that grow in hydric soils), 2) hydric soil (i.e., soils that are commonly 

35 flooded or saturated), and 3) wetland hydrology (USACE, 2008). 

36

37 Many of the potential wetland areas delineated during the 2010 field surveys were small 

38 depressions (<0.04 ha [0.1 ac]) that were in close proximity to each other but were distinct 

39 depressions separated by upland vegetation. A significant number of these small-depression 

40 areas appeared to be influenced by ground water, receiving seepage from the Lance Formation, 

41 which outcrops in the vicinity. These potential wetlands were classified according to Cowardin 

42 et al. (1979) to more accurately describe the types of potential wetlands present within the Ross 

43 Project area (Strata, 2011a). Approximately 93 percent of the potential wetlands were man44 made (i.e., diked or excavated). A significant majority of these are preliminarily classified as 

45 Palustrine, Aquatic Bed, Seasonally Flooded (PABFh) or Diked. Of the areas designated as 

46 PABFh, approximately half were areas of open water. In addition, there were approximately 2.1 

47 ha [5.1 ac] (6,750 linear m [22,130 linear ft] x an average 3-m- [10-ft]-wide channel) of “Other 

48 Waters of the U.S.” identified within the Ross Project area (Strata, 2011a). 
DRAFT Affected Environment

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1 A wetlands delineation report for the Ross Project was submitted to the USACE Omaha District 

2 in Cheyenne, Wyoming, during September 2010 (Strata, 2011a). The USACE provided the 

3 Applicant a letter on December 9, 2010, that verified the following (USACE, 2010):

4

5 ■ The methods used to identify wetlands and other surface waters were consistent with the 

6 USACE’s Wetland Delineation Manual and its current supplements. 

7 ■ Exhibit 1 in the wetlands delineation report, entitled Wetlands and Other Waters of the US. 

8 Delineation for the Proposed Ross ISR Project Oshoto, Wyoming (Wetland Map) (dated 

9 August 23, 2010), provided an accurate depiction of the boundaries of all wetlands and 

10 other waters within the Ross Project area.

11 ■ All of the wetlands and channeled waterways identified in the delineation report are 

12 connected or adjacent to the Little Missouri River, a navigable water, and are thus likely to 

13 be Waters of the U.S. as defined in 33 CFR Part 328. 

14

15 USACE’s final determination of specific wetland areas would not occur until the Applicant

16 applies for coverage for specific construction activities, such as pipeline installation and access17 road stream-channel crossings. At that time, the Applicant would be required to provide a site18 specific mitigation plan for its disturbance of jurisdictional wetlands (i.e., those wetlands that are 

19 under the jurisdiction of the USACE).

20

21 3.5.3 Ground Water

22

23 Regional Ground-Water Resources

24

25 The Applicant presents a description of the regional hydrogeology based upon published 

26 literature in its license application (Strata, 2011a; Strata, 2011b). The site-specific hydrogeology 

27 of the Lance Formation and the associated stratigraphy underlying the Ross Project area is not 

28 described in the GEIS; thus, detailed information is included here. Water-bearing bedrock 

29 intervals in the eastern Powder River Basin range in age from Precambrian to Paleocene (see 

30 Figure 3.7). Regionally, recharge occurs in the outcrop areas, with ground water moving away 

31 from the outcrop into the Basin. Due to the geologic dip of the units, horizons that are 

32 accessible near the Black Hills uplift are deeply buried in the Basin’s center about 125 km [75 

33 mi] west from the Ross Project area (Hinaman, 2005).

34

35 Within the northeast corner of Wyoming there are a number of water-bearing intervals tapped by 

36 municipalities and industrial users (Strata, 2011a; Langford, 1964). Below the Fox Hills 

37 aquifers, the Minnelusa Formation (210 – 270 m [700 – 900 ft] thick), and the underlying 

38 Madison Formation (90 – 270 m [300 – 900 ft] thick) are the most significant aquifers (Whitcomb 

39 and Morris, 1964). The Minnelusa and Madison aquifers are recharged at the outcrop in the 

40 area of the Black Hills uplift. Ground-water flow in all aquifers is from the recharge areas along 

41 the outcrop, westward towards the center of the Powder River Basin. Flow directions are locally 

42 modified by pumping wells. The Minnelusa Formation has received aquifer exemptions in 

43 portions of Campbell County, which allow it to be used for waste-water disposal (EPA, 1997).

44

45 The Minnelusa Formation is also an important hydrocarbon reservoir interval in the areas of the 

46 Powder River Basin that are west of the Ross Project (De Bruin, 2007). At the Ross Project 

47 area, the Minnelusa Formation is approximately 1,860 m [6,100 ft] bgs (Strata, 2011a). It is 
DRAFT Affected Environment

3-31

1 separated from the ore zone by 1,680 m [5,500 ft] of sandstone, claystone and shale, most 

2 notably the Pierre Shale which is over 600 m [2,000 ft] thick under the Ross Project area as 

3 noted in SEIS Section 3.4 (Whitcomb and Morris, 1964).

4

5 Water-supply wells in the Madison Formation have reported yields of up to 3,785 L/min [1,000 

6 gal/min]; the Formation is an important source of drinking water for the communities of Gillette 

7 and Moorcroft. The city of Gillette operates a wellfield consisting of ten wells north of the town 

8 of Moorcroft, yielding 35,204 L/s [9,300 gal/s] from a depth of approximately 760 m [2,500 ft]. 

9 The water is piped approximately 53 km [33 mi] to Gillette and blended with locally-produced 

10 ground water from the Fort Union Formation and to a lesser degree from wells completed in the 

11 Lance and Fox Hills Formations. Other towns in the vicinity (e.g., Moorcroft, Sundance, Upton, 

12 Newcastle, and Hulett) also use the Madison Formation for municipal water supply (Strata, 

13 2011a). In the vicinity of Gillette, the Fox Hills and Lance Formations are typically targeted by 

14 industrial users, while smaller municipalities, subdivisions, and improvement districts west of 

15 Ross Project area use wells completed within the shallower Fort Union Formation. 

16

17 Local Ground-Water Resources

18

19 The detailed geologic stratigraphy and its relationship to the corresponding hydrology are 

20 illustrated in Figure 3.14. The detailed stratigraphic sequence from the land surface to the 

21 confining interval below the ore zone is, in descending order: recent, unconsolidated, surficial 

22 deposits including residual soils, colluvium, and alluvium; Lance Formation; Fox Hills Formation; 

23 and Pierre Shale (see also SEIS Section 3.4). Figure 3.14 illustrates the geophysical log and 

24 corresponding lithology obtained from type exploration drillhole No. RMR008, the location of 

25 which is shown in Figure 3.14. This particular drillhole was chosen as the “type log” by the 

26 Applicant for the Ross Project because of the clarity of the geophysical logs and the associated 

27 stratigraphic descriptions from land surface to the top of the Pierre Shale (Strata, 2011a). 

28

29 Within the Ross Project there are four named aquifers existing between the land surface and 

30 the Pierre Shale. The correspondence between stratigraphic and hydrologic units, and the 

31 related nomenclature, is summarized in Table 3.4. 
DRAFT Affected Environment

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1

Source: Strata, 2012a.

Figure 3.14

Stratigraphic and Hydrogeologic Units at Ross Project Area
DRAFT Affected Environment

3-33

1

Table 3.4

Geologic Units, Stratigraphic Horizons, and Hydrologic Units 

of Ross Project Area

Geologic Unit

Stratigraphic

Horizon Hydrologic Unit

Lance Formation and/or 

Recent Alluvium/Colluvium Qal/LA/LB SA 

(Surface Aquifer)

Lance Formation

LD-LG Lance Units

(Aquitard)

LK-LM SM 

(Shallow-Monitoring Aquifer)

LN-LS Sandstone within Confining Unit

LC Upper Confining Unit

LT-LTS OZ

(Ore-Zone Aquifer)

Fox Hills Formation

FH

BFH Lower Confining Unit

(Aquitard)

BFS DM

(Deep-Monitoring Aquifer)

BFH/FS Sandstone within Confining Unit

Pierre Shale KP Regional Confining Unit 

(Aquitard)

2 Source: Strata, 2012b.

3

4 The surficial aquifer, or the SA interval, is the “water-table” aquifer within the Ross Project area. 

5 It consists of the uppermost water-bearing interval within the upper Lance Formation and the 

6 alluvium of the Little Missouri River and Deadman Creek. Ground-water levels range from near7 surface in the river valleys to over 15 m [50 ft] bgs in topographically higher areas.

8

9 The sandstones of the lower Lance Formation (LT intervals) make up the upper portion of the 

10 ore zone (i.e., ore-zone [OZ] aquifer) (see Figure 3.14). The LT sands range in thickness from 9 

11 – 12 m [30 – 40 ft] and show hydraulic continuity beneath the Ross Project area. Above the LT 

12 sands is a shale layer varying in thickness from 6 – 24 m [20 ft – 80 ft], locally called the LC 

13 interval aquitard. The Applicant designates the LC aquitard as the “upper confining unit.” The 

14 LC aquitard serves as a confining unit that separates the uranium-mineralized sandstones of the 

15 FH and LT horizons and the OZ aquifer, from the water-bearing unit above (see Figure 3.14). 

16

17 The water-bearing sands above the upper confining unit is referred to as the shallow-monitoring 

18 (SM) unit, or SM aquifer, and is composed of the LM- through LK-horizon sandstones. Above 

19 the SM aquifer is a sequence of thin sands, shales, and silts. Many of the thin sandstones 
DRAFT Affected Environment

3-34

1 contain water; however, these sandstones are generally discontinuous and, while they may be 

2 used locally for stock and domestic wells, they are not regionally extensive.

3

4 The Lance Formation is recharged at the outcrop and at the subcrop beneath the alluvium in the 

5 valley of the Little Missouri River and its tributaries. Natural ground-water flow would be 

6 expected to be westward from the outcrop toward the Basin. 

7

8 At the Ross Project area, the thickness of the Fox Hills Formation is approximately 46 m [150 ft], 

9 with local variations of up to15 m [50 ft] or more. The Fox Hills Formation consists of an upper 

10 sandstone unit (i.e., FH horizon) and a lower sandstone unit (i.e., FS horizon) which are 

11 separated by an intervening shale, claystone, and mudstone interval (i.e., BFH horizon) 

12 containing the BFS sandstone unit (see Figure 3.14). Uranium mineralization primarily occurs 

13 within the Fox Hills Formation’s sands, although in localized areas mineralization occurs within 

14 the overlying Lance Formation’s (i.e., LT horizon) sandstone. 

15

16 The FS and BFS sandstones represent the only water-bearing units within the lower Fox Hills 

17 Formation (see Table 3.4). Both sand units are believed to be continuous throughout the Ross 

18 Project area, although in places they are relatively thin. The BFS horizon is the nearest aquifer 

19 below the uranium-bearing sandstone (the FH horizon and also known as the ore zone) in the 

20 upper Fox Hills Formation, and in terms of uranium-recovery operations, it is referred to as the 

21 deep-monitoring (DM) interval, or the DM aquifer. It is separated from the FH sand (i.e., the ore 

22 zone) above and the FS (basal sandstone) below by a shale, claystone, and mudstone (BFH 

23 horizon). The Applicant provides potentiometric contours for the DM interval in its ER (see 

24 Figure 3.15) (Strata, 2011a).

25

26 The Pierre Shale yields very little water; it is considered regionally as a confining unit (NRC, 

27 2009b; Whitehead, 1996). No wells are known to be completed within the Pierre Shale at the 

28 Ross Project area.

29

30 The FH horizon sandstones within the upper Fox Hills Formation contain uranium and are the 

31 primary uranium-recovery target interval for the Proposed Action. The Applicant has designated 

32 the OZ aquifer as consisting of the FH sandstones with the overlying lower Lance Formation 

33 sandstones (LT horizon). The lithologies of the ore zone range from thick-bedded, blocky 

34 sandstones to thin, interbedded 

35 sandstones, siltstones, and shales. 

36 The OZ aquifer is underlain by 

37 claystone of the Fox Hill Formation

38 (i.e., BFH interval). Within the Ross 

39 Project area, this ore-zone interval 

40 ranges from 27 – 55 m [90 – 180 ft] 

41 thick (see Figure 3.14). Thin, silty, 

42 and clayey sandstone comprises the 

43 DM aquifer. The Applicant

44 designates the BFH aquitard above 

45 the DM aquifer and below the ore

46 zone as the “lower confining unit.”

47

What terms are used to describe hydrologic 

characteristics? 

Transmissivity: This term is used to define the flow rate of 

water through a vertical section of an aquifer, considering a 

unit width and extending the full saturated height of the 

aquifer under unit hydraulic gradient. Transmissivity is a 

function of an aquifer’s saturated thickness and hydraulic 

conductivity.

Hydraulic Conductivity: This term represents a measure of 

the capacity of a porous medium to transmit water. It is used 

to define the flow rate per unit cross-sectional area of an 

aquifer under unit hydraulic gradient.

Storativity: This term is used to characterize the capacity of 

an aquifer to release ground water from storage in response 

to a decline in water levels.
DRAFT Affected Environment

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1

Figure 3.15

Potentiometric Contours of Ground Water in Ore-Zone Aquifer

Source: Strata, 2012a.
DRAFT Affected Environment

3-36

1 Isopachs of this structure show that it ranges in thickness from less than 3 m [10 ft] to more than 

2 30 m [100 ft] (Strata, 2011a). Above the ore zone, the mudstone and claystone of the Lance 

3 Formation form the upper confining unit, as noted above, ranging in thickness from less than 6 

4 m [20 ft] to more than 24 m [80 ft] (see Figure 3.14). 

5 The FH sandstones, shales, and silts have been studied extensively through both core analysis 

6 and aquifer tests. Seven pumping tests targeting the ore zone were performed by the Applicant

7 at six separate well clusters. Applicable methodology and testing were used and those results 

8 are shown in Table 3.5 (and additional details can be found in Strata, 2011a).

9

Table 3.5

Ore-Zone Aquifer Hydrogeologic Characteristics

Transmissivity

m2

/day [ft2/day]

Hydraulic 

Conductivity

cm/s [ft/day]

Storativity

(Unitless)

Minimum 0.353 [3.80] 4.59E-05 [0.13] 4.00E-06

Maximum 34.2 [368] 2.69E-03 [7.62] 1.50E-04

Median 8.20 [88.3] 1.25E-03 [3.55] 6.10E-05

Geometric Mean 6.10 [65.6] 6.74E-04 [1.91] 4.50E-05

Average 8.15 [87.8] 1.15E-03 [3.26] 6.70E-05

10 Source: Addendum 2.7-F, Table 3, in Strata, 2011a.

11

12 The aquifer properties determined by the 2010 tests are comparable to results reported for 

13 previous pumping tests within the Ross Project area (Strata, 2011b).

14

15 The Applicant developed a static piezometric surface (i.e., a map showing the static water levels 

16 expressed as feet above sea level) for the ore-zone aquifer (see Figure 3.15). The ore zone’s 

17 potentiometric surface shows a distinct cone of depression near the No. 21-19 well cluster that 

18 has resulted from 30 years of ground-water withdrawals by oil-field water-supply wells 

19 completed in the OZ aquifer. This pumping has changed the hydraulic gradient and the 

20 direction of ground-water flow throughout most of the Ross Project area. The potentiometric 

21 surface near the No. 34-7 well cluster, which is farthest from the oil-field water-supply wells that 

22 have been pumping for 30 years, has been least affected by such pumping. Based upon the 

23 Applicant’s estimates, approximately 46 m [150 ft] of drawdown (i.e., the decline in water level) 

24 in the ore-zone aquifer has occurred in the vicinity of the No. 21-19 well cluster since pumping 

25 began in 1980 for local oil-field water-flood operations (Strata, 2011b). An updated map of the 

26 ore zone’s piezometric surface prepared by the Applicant using a ground-water model provides 

27 additional detail of the drawdown associated with the withdrawals from the Merit Oil Company’s 

28 (Merit’s) three water supply wells (Strata, 2012b).
DRAFT Affected Environment

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1 The Applicant also calculated horizontal gradients and vertical-head differences between the 

2 OZ, SM, and DM aquifers (Strata, 2011a). Horizontal gradients in the OZ aquifer are toward the 

3 oil-field water-supply wells, and they range from 0.009 – 0.025, with the steeper gradients being 

4 in the vicinity of the oil-field water-supply wells. Vertical-head differences between the OZ and 

5 the DM aquifers range from 6 m [20 ft] downwards in the northwestern portion of the Ross 

6 Project area to 3 m [10 ft] upwards in the area of the oil-field water-supply wells. Vertical 

7 gradients are downwards from the SM to the OZ aquifers, with head differences ranging from 15 

8 – 46 m [50 – 150 ft].

9

10 The OZ aquifer remains a confined aquifer across the Ross Project area, with potentiometric 

11 heads ranging from approximately 46 m [150 ft] to more than 122 m [400 ft] above the top of the 

12 ore zone (Strata, 2011a). Recharge to the Fox Hills Formation and, hence, the OZ aquifer, is 

13 from precipitation along the outcrop, ground water from the subcrop beneath alluvium in the 

14 valley of the Little Missouri River and its tributaries, and from leakage from the overlying Lance 

15 Formation. Under current conditions, discharge is to the oil-field water-supply wells. 

16

17 Continuous measurement of water levels for the period April to October 2010 were recorded by 

18 the Applicant in six monitoring wells completed in the OZ aquifer and are presented graphically 

19 by the Applicant in its TR (Strata, 2011b). The hydrograph for Well 34-7OZ, which is located 

20 farthest from the oil-field water-supply wells, displays the least variation. The variability in the 

21 ore-zone-well hydrographs is a function of the well locations relative to the oil-field water-supply 

22 wells in Sections 18 and 19. The wells located closest to this area (Wells 21-19OZ, 34-18OZ, 

23 14-18OZ, and 42-19OZ) display water-level fluctuations that are related to pumping of the 

24 water-supply wells. Pumping starts and stops that occurred in late June though early July 2010 

25 are apparent on hydrographs from these wells. A rapid water-level rise (over 4.6 m [15 ft] in 

26 Well 21-19OZ) in late September 2010 was attributed to a temporary cessation of pumping. This 

27 was followed by a rapid decline in the water level, which was interpreted as an indication of 

28 resumption of pumping.

29

30 Other than the aquifer testing that took place over the period above, other recorded 

31 perturbations are related to sampling events and barometric fluctuations. The barometric 

32 fluctuations are less than 0.2 m [0.5 ft]. During January through October 2010, the hydrograph 

33 for Well 34-7OZ showed a steady increase of approximately 0.6 m [2 ft]. The cause of this 

34 increase has not been identified; similar patterns have not been seen in other ore-zone well 

35 hydrographs. The hydrograph for Well 12-18OZ varies within a range of approximately 0.76 m 

36 [2.5 ft]. Most of the water-level changes are interpreted as responses to barometric pressure 

37 changes. However, fluctuations in the late June though early July time period coincide with 

38 pumping-related water-level changes observed in the group of four wells discussed above.

39

40 The shale, claystone, and mudstone interval, the BFH horizon and lower confining unit, 

41 separates the DM aquifer from the FH horizon. This low-permeability unit ranges in thickness 

42 from less than 3 m [10 ft] to 24 m [80 ft]. Vertical hydraulic conductivities for this interval are 

expected to be comparable to that of the Pierre Shale (i.e., 2 x 10-7 cm/s [5 x 10-4 43 ft/day] or less), 

44 based on their similar lithologies.

45

46 Pumping tests were performed on six well clusters with pumping from the OZ aquifer and 

47 monitoring of the SA, SM, and DM aquifers. No effects from pumping were measured in any of 

48 the overlying SA or SM wells. Water levels in two of the six underlying DM wells (Nos. 14-18DM 
DRAFT Affected Environment

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1 and 34-18DM) declined slightly during pumping. The lower confining unit is 9 – 15 m [30 ft – 50 

2 ft] thick in the portions of the Ross Project area where these wells are located. The response of 

3 the DM-completed wells has been interpreted by the Applicant as being due to vertical leakage 

4 across the lower confining unit via drillholes that are in close proximity to the pumping-test well 

5 cluster that have not yet been located and plugged. Prior to the Applicant’s conducting the 

6 aquifer test at Well 12-18, all exploration drillholes in the vicinity of that well cluster were located 

7 and plugged, and no response of the DM-aquifer well was observed during that pumping test. 

8

9 Communication between the OZ and DM aquifers in locations where the lower confining unit 

10 has been breached was demonstrated by: 1) the responses observed in the DM zone for two 

11 pumping tests, where old exploration drillholes had not been plugged and 2) the similarities in 

12 the potentiometric heads in the DM, OZ and SM aquifers in the vicinity of the oil-field water13 supply wells, which are completed in both the OZ and DM intervals. To prevent communication 

14 between aquifers during uranium-recovery operation, the Applicant proposes to actively locate 

15 and plug all exploration drillholes prior to beginning wellfield operations. The Applicant

16 proposes to actively locate and plug all exploration wells prior to beginning wellfield operation.

17

18 Ground-Water Quality

19

20 The Applicant has compiled regional water-quality data listed in the USGS’s NWIS from 16 wells 

21 located in Crook and Campbell Counties that were completed in the Lance and Fox Hills 

22 aquifers (Strata, 2011a; USGS, 2012b). Data from these wells show a water quality of the 

23 Lance and Fox Hills aquifers that is slightly alkaline (i.e., median pH of 8.4) with a median TDS 

24 of 1,130 mg/L, with sodium and bicarbonate as the dominant dissolved species. 

25

26 The water quality of shallow ground water from alluvial deposits on the Lance Formation is 

27 dominated by sodium, sulfate, and bicarbonate with moderate levels of TDS of approximately 

28 1,200 – 1,400 mg/L (Langford, 1964). Rankl and Lowry (1990) noted that the water quality in 

29 the aquifer sequence through the Lance and Fox Hills Formations depends upon the 

30 stratigraphy and varies according to well depth. As well depths increase from 30.5 – 152 m 

31 [100 – 500 ft], TDS in the waters decrease sharply due to declining concentrations of calcium, 

32 magnesium, and sulfate. Water from wells at depths of 152 m [500 ft] or greater are dominated 

33 by bicarbonate and sodium.

34

35 The deep-injection-well UIC Class I permit application for the Ross Project contains estimates of 

36 water quality in deeper formations, from the Minnelusa through the Cambrian Formations 

37 (WDEQ/WQD, 2011). The Minnelusa, Deadwood, and Flathead Formations are expected to 

38 have TDS concentrations greater than 10,000 mg/L, while the Madison Formation likely has a 

39 TDS concentration around 1,000 mg/L in the vicinity of the Ross Project area. 

40

41 To comply with the requirements of 10 CFR Part 40, Appendix A, Criterion 7, the Applicant has 

42 collected pre-licensing baseline ground-water-quality data from the site characterization of the 

43 Ross Project area. These data originate from three sources: 1) the Applicant’s own baseline 

44 site-characterization monitoring network at the Ross Project and the respective analytical data; 

45 2) existing water-supply-wells sampling and analysis data; and 3) historical data from the former 

46 Nubeth operation (Nuclear Dynamics, 1978). The first source of ground-water quality data is 

47 the Applicant’s own ground-water-monitoring network which it constructed in 2009 and 2012 

48 and which consists of six monitoring-well clusters and four piezometers (Strata, 2011a). Each 
DRAFT Affected Environment

3-39

1 well cluster includes four monitoring wells targeting the OZ aquifer and the aquifer units above 

2 the ore zone (SA and SM) and below the ore zone (DM) (see Figure 3.14). The Applicant

3 provided construction details of the wells and methods used for ground-water sampling in its ER 

4 (Strata, 2011a). The four piezometers in the SA were installed in the portion of the Ross Project 

5 area proposed for the central processing plant (CPP) and surface impoundments (Strata, 

6 2011a).

7

8 Analytical data from the 2010 quarterly samples are provided in the Applicant’s ER and TR 

9 (Strata, 2011a; Strata, 2011b). Water-quality data from samples collected in 2011 and 

10 submitted to WDEQ/LQD are provided in information received subsequently from the Applicant

11 (Strata, 2012a). The data from 2011 are generally consistent with the 2009 and 2010 data, 

12 indicating a representative characterization of ground-water quality. The data are summarized 

13 in the following paragraphs.

14

15 The average concentrations of the major cations and anions, in addition to the median field 

16 measurements of pH and average dissolved-oxygen measurements, are presented on the next 

17 page in Table 3.6. Dissolved solids (TDS) in the ground water at the Ross Project area are 

18 predominately bicarbonate-sulfate-sodium, which differs from typical ground water described in 

19 the GEIS, which is the bicarbonate-sulfate-calcium type. The pH conditions of greater than 8.5 

20 are consistent with bicarbonate water, and dissolved oxygen levels of less than 5 mg/L suggest 

21 low-oxygen conditions. These two parameters are typical of uranium-bearing aquifers (NRC, 

22 2009b).

23

24 The water quality data indicates distinctive water quality in each aquifer unit, i.e., the SA, SM, 

25 OZ, and DM. The distinctive water quality is made possible by the stratigraphic layers between 

26 the aquifer units that prevent vertical movement of water between the units. Average values of 

27 TDS in Strata’s ground-water baseline monitoring network range from 730 mg/L in the SA to 

28 1574 mg/L in the OZ. Ground-water from piezometers in the SA show that the TDS increases 

29 sharply with increasing distance from the Little Missouri River (Strata, 2011a).

30

31 The effects on Strata’s pre-licensing baseline water quality from Nubeth can be evaluated by 

32 comparing the Strata’s data with baseline data reported by Nuclear Dynamics (1978). The data 

33 from Strata (2011a, 2012a) include all four aquifer units. Nuclear Dynamics (1978) reports data 

34 from only the ore zone and the aquifer above the ore zone which is likely equivalent to the SM. 

35 The comparison shows that the TDS in the SM and OZ have decreased since 1978 (see also 

36 SEIS Section 5.7.2).

37

38 Table 3.7 summarizes the concentrations of metals, radiological parameters, ammonium, and 

39 fluoride measured by Strata in the aquifer units. With a few exceptions, the 1978 mean values 

40 are within the range of values reported by Strata (2011a, Strata, 2012a). Strata’s pre-licensing 

41 baseline concentrations of arsenic, radium-226, and gross beta are slightly lower in the ore zone 

42 than was measured in 1978 (Table 3.7). Strata’s concentrations of cadmium, lead and nickel 

43 are slightly lower in both the ore zone and the aquifer above the ore zone than in 1978. 
DRAFT Affected Environment

3-40

1

Table 3.6

Average Concentrations of Major Cations and Anions in Ground Water 

from the Ore-Zone (OZ) Aquifer and Aquifers Above (SM & SA) and Below (DM) the Ore Zone†

Constituent Units

Ross Project 

Monitoring-Well Data

(Strata, 2011a; Strata, 2012a)

Nubeth Data

(Nuclear 

Dynamics, 1978)

Surficial 

Aquifer

(SA)

ShallowMonitoring 

Aquifer

(SM)

Ore-Zone 

Aquifer

(OZ)

DeepMonitoring 

Aquifer

(DM)

Ore

Zone

Above

Ore 

Zone

Bicarbonate mg/L 339 449 583 295 592 653

Calcium mg/L 21 2 6 3 6.2 6

Carbonate mg/L N/A 98 26 103 22 17

Chloride mg/L 29 4 7 491 10 6

Magnesium mg/L 13 <1** 2 <1** 2.7 2.7

Potassium mg/L 12 15 6 19 3.2 3.9

Sodium mg/L 224 417 545 520 622 592

Sulfate mg/L 172 318 602 31 715 567

Total 

Dissolved 

Solids (TDS) mg/L 730 1145 1574 1321 1629 1498

Dissolved 

Oxygen (DO) mg/L 3.2 3.9 2.8 4.7 N/A*** N/A***

pH Std. Units 8.6 9.15 8.7 9.4 8.8 8.6

2 Source: Strata, 2011a; Strata, 2012a; Nuclear Dynamics, 1978.

3 Notes:

† 4 All values are mean concentrations, except for pH from Strata data, which is the median value, and pH reported in 

5 Nubeth, which is a mean value.

† 6 Shading indicates a value greater than WDEQ and U.S. Environmental Protection Agency (EPA) 

7 Water Quality Standards.

8 * 34 percent of the 32 reported concentrations were below the detection limit, which precluded calculation of an 

9 average or median value; minimum and maximum values for carbonate concentration in mg/L were less than 5 and 

10 218 mg/L, respectively, for this dataset.

11 **“<” = “Less than,” where the value following the “<” is the detection limit.

12 ***N/A = Not available.
3-41

Table 3.7

Summary of Water Quality of Ground Water from the Ore-Zone (OZ) Aquifer 

and Aquifers Above (SA & SM) and Below (DM) the Ore Zone†

2009, 2010, and 2011 Data from Ross Project Monitoring Wells Nos. 12-18, 14-18, 21-19, 34-7, 34-18, and 42-19 

(As reported in Strata, 2011a; Strata, 2012a.)

Constituent* Units

Ross Project Monitoring-Well Data 

SA SM OZ DM 

Min Max Min Max Min Max Min Max 

Ammonia mg/L <0.1** 0.6 <0.1 2.8 <0.1 0.8 <0.1 3.9 

Arsenic mg/L <0.005 <0.005 <0.005 0.023 <0.005 <0.005 <0.005 0.014 

Barium mg/L <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 

Boron mg/L <0.1 0.3 0.2 0.8 0.3 0.6 0.3 1 

Cadmium mg/L <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 

Chromium mg/L <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Copper mg/L <0.01 <0.01 <0.01 0.02 <0.01 <0.01 <0.01 <0.01 

Fluoride mg/L 0.1 0.8 0.8 2.1 0.2 1.3 0.8 1.6 

Iron mg/L <0.05 0.66 <0.05 0.21 <0.05 0.69 <0.05 0.4 

Lead mg/L <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 

Mercury mg/L <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 

Manganese mg/L <0.02 0.36 <0.02 0.88 <0.02 0.06 <0.02 0.37 

Molybdenum mg/L <0.02 0.07 <0.02 0.05 <0.02 <0.02 <0.02 0.06 

Nickel mg/L <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Selenium mg/L <0.005 0.008 <0.005 0.017 <0.005 0.009 <0.005 0.03 

Silver mg/L <0.003 0.006 <0.003 0.011 <0.003 <0.003 <0.003 0.005 

Uranium mg/L <0.001 0.007 <0.001 0.004 0.005 0.109 <0.001 0.003 

Vanadium mg/L <0.02 <0.02 <0.02 0.02 <0.02 <0.02 <0.02 <0.02 

Zinc mg/L <0.01 1.32 <0.01 0.03 <0.01 0.02 <0.01 0.09 

Radium-226 pCi/L <0.2 0.5 <0.2 3.7 0.6 12.1 <0.2 0.7 

Radium-228 pCi/L <1 1.8 <1 12.27 <1 1.6 <1 2.2 

Gross Alpha pCi/L <6 13.8 <7 12.2 <5 222 <14 28.3 

Gross Beta pCi/L <8 17.6 <8 319*** <8 46.8 <20 41 

 Source: Strata, 2011a; Strata, 2012a; Nuclear Dynamics, 1978. 1 Notes on next page. 2
DRAFT Affected Environment

3-42

1 Notes for Table 3.7:

† 2 Analytical results are presented as minimum and maximum values for each constituent; the number of

3 measurements that are less than the detection level precludes calculation of mean concentrations.

† 4 Shading indicates a value greater than WDEQ and EPA Water Quality Standards.

5 *All constituents reported as dissolved concentrations (i.e., the samples were filtered), except ammonia and fluoride.

6 ** “<” = “Less than,” where the value following the “<” value is the detection limit.

7 “N/A” = Datum not available.

8 ***319 appears to be an anomalous value; the next lowest value is 42.5.

9

10 The similarity between the pre-licensing baseline concentrations in the ore zone and aquifer 

11 above the ore zone suggests that Nubeth did not alter the baseline water quality. Table 3.8 

12 presents the WDEQ and EPA water-quality standards for constituents that were present in 

13 Strata’s that were found to exceed the standards in Strata’s pre-licensing baseline data 

14 (WDEQ/WQD, 2005b; 40 CFR Part 41). Concentrations of constituents that exceed the 

15 standards are indicated by shading in Tables 3.6 and Table 3.7. 

16

Table 3.8

Water-Quality Standards Exceeded 

in Ground Water at the Ross Project

(Pre-Licensing Baseline)

Water-Quality

Constituent Units

WDEQ

Class I

Domestic

WDEQ

Class II

Agriculture

EPA

Primary

MCL

EPA 

Secondary

MCL

Ammonia mg/L 0.5 N/A* N/A N/A

Arsenic mg/L 0.05 0.1 0.01 N/A

Boron mg/L 0.75 0.75 N/A N/A

Chloride mg/L 250 100 N/A 250

Iron mg/L 0.3 5 N/A 0.3

Manganese mg/L 0.05 0.2 N/A 0.05

Selenium mg/L 0.05 0.02 0.05 N/A

Sulfate mg/L 250 200 N/A 250

Total Dissolved 

Solids (TDS) mg/L 500 2000 N/A 500

Uranium mg/L N/A N/A 0.03 N/A

Radium226 + 228 pCi/L 5 5 5 N/A

Gross Alpha pCi/L 15 15 15 N/A

17 Source: WDEQ/WQD, 2005b.

18 Notes: 

19 * N/A = Not applicable.

20 Per the WDEQ/LQD Hydrology Guideline No. 8 and NRC Regulatory Guide 4.14, the water-quality data 

21 produced by the Applicant and used to compare with the water-quality standards are dissolved concentrations 

22 except for ammonium, chloride, fluoride, sulfate, and TDS (WDEQ/LQD, 2005b; NRC, 1980).
DRAFT Affected Environment

3-43

1 Typical of uranium-bearing aquifers described in the GEIS (NRC, 2009b), the average TDS of 

2 each aquifer unit associated with Ross Project area exceed EPA’s respective Secondary 

3 drinking water maximum contaminant levels (MCLs) of 500 mg/L, but they are within all the 

4 upper limits set by WDEQ for Class II Agriculture and Livestock Classes of Use (see Tables 3.6 

5 and 3.8) (WDEQ/WQD, 2005b). The two upper aquifers, SA and SM, contain lower TDS than 

6 the lower units, and the OZ aquifer contains the highest average TDS. 

7

8 Comparison of the metals, radiological parameters, ammonium, and fluoride to EPA’s MCLs for 

9 drinking water and WDEQ standards are provided in Tables 3.7 and 3.8. Ammonia was 

10 measured in all four aquifer units at concentrations greater than WDEQ’s standard for domestic 

11 use, 0.5 mg/L. Iron and manganese are present in all four aquifer units in concentrations 

12 greater than WDEQ’s standard for domestic use and EPA’s secondary MCL for drinking water. 

13 Arsenic was measured at concentrations greater than EPA’s primary drinking water standard in 

14 the SM and DM but less than WDEQ’s standard for domestic use. Boron was present at 

15 concentrations greater than the WDEQ standard for domestic use in the SM and DM. Uranium 

16 and radium-226 were present in the OZ at concentrations greater than the standards (see Table 

17 3.8). Gross alpha exceeded the standards in the OZ and DM aquifer units.

18

19 As part of its ground-water sampling and analysis efforts, the Applicant identified 29 currently 

20 operable water-supply wells within the Ross Project area and the surrounding 2-km (1.2-mi) 

21 area (Strata, 2011a). These wells included two industrial wells, 12 domestic wells, and 15 stock 

22 wells. These well locations are shown in the Applicant’s ER (Strata, 2011a).

23

24 The two industrial wells, completed at depths of 163 m and 229 m [536 ft and 750 ft], were 

25 permitted in the early 1980s and provide water for enhanced oil recovery (EOR). Water used in 

26 EOR is injected into the oil-bearing rock to displace oil from the rock, thus allowing the oil to be 

27 pumped to the surface. Well No. 19X-18 was originally used by Nubeth as a recovery well for 

28 its research and development activities, before being converted to a water-supply well for the 

29 nearby oil production. The Applicant’s review of the well permit reports listed in the WSEO 

30 database during 2010 determined general information about each well (WSEO, 2006; Strata, 

31 2011a). Completion depths of permitted stock wells range from 10 – 93 m [40 – 304 ft]. 

32 Domestic wells are generally deeper than the stock wells, ranging from 46 – 180 m [150 – 600 

33 ft]. The limited information available on these wells precluded a determination of which aquifer 

34 was supplying water to the domestic wells.

35

36 The water-supply wells were sampled in consecutive quarters in 2009 and 2010 with the same 

37 methods established for the monitoring wells (Strata, 2011a). The results of the water-quality 

38 analyses are provided in the Applicant’s ER (Strata, 2011a; Strata, 2011b). Comparison 

39 between the measured water quality and WDEQ’s standards and EPA’s drinking- water 

40 standards are also provided in the Applicant’s ER (WDEQ/WQD, 2005b; 40 CFR Part 141; 

41 Strata, 2011a). As described below for each type of well, these analyses showed that the local 

42 water supply’s contaminants generally exceeded EPA’s drinking water standards and often 

43 exceeded Wyoming’s less stringent quality standards for agricultural use. 

44

45 Domestic Wells

46

47 TDS in samples from the domestic wells consistently exceeded the Wyoming Class I (Domestic) 

48 use and the EPA Secondary MCL standards. Sulfate exceeded the Wyoming Class I, the 

49 Wyoming Class II and the EPA Secondary MCL standards in 7 of the 13 wells sampled. Gross 
DRAFT Affected Environment

3-44

1 alpha in excess of the Wyoming Class I and Class II standards, as well as the EPA Primary 

2 MCL of 0.55 Bq/L [15 pCi/L], was measured in samples from 4 of the 13 domestic wells. The 

3 Wyoming Class I and the EPA Secondary MCL iron standards were exceeded in two of the 

4 wells.

5

6 Industrial Wells

7

8 Samples from the industrial wells exceeded the Wyoming Class II standard and the EPA 

9 Secondary MCL standards for TDS and sulfate. The Wyoming Class II and the EPA MCL 

10 standards were exceeded in Well No. 19XX18 for radiological parameters: uranium, radium11 226+228, and gross alpha. The gross-alpha standard was also exceeded in samples from Well 

12 No. 22X-19.

13

14 Stock Wells

15

16 The water quality of stock wells is variable. TDS often ranged from 370 to 1,610 mg/L, often 

17 exceeding the EPA Secondary MCL standard, but also consistently less than the Wyoming 

18 Class II use standard of 2,000 mg/L. Sulfate, ranging from 28 to 679 mg/L, often exceeded the 

19 Wyoming Class II and the EPA Secondary MCL standards. Gross alpha exceeded both the 

20 Class II standard and the MCL in 7 of the 15 stock wells. Selenium exceeded the Wyoming 

21 Class II and the EPA Primary MCL standards in one well.

22

23 Ground-Water Uses

24

25 In order to assess historical and current ground-water use, ground-water rights and unregistered 

26 water wells were investigated by the Applicant within the Ross Project area and the surrounding 

27 3.2-km [2-mile] vicinity. Sources of data included WSEO-registered wells, landowner interviews, 

28 and field investigations (WSEO, 2006). The search revealed 119 ground-water rights and 

29 unregistered wells. The locations and uses of these wells are summarized in the Applicant’s ER 

30 (Strata, 2011a). Historical ground-water use began with the first domestic and livestock well in 

31 1918. From approximately 1918 – 1977, ground water was used primarily for domestic and 

32 livestock consumption, with lesser amounts of water used for irrigation. 

33

34 In 1977, Nubeth permitted 14 monitoring and industrial-use wells associated with its research 

35 and development operation. In addition, between 1980 and 1991, many industrial and 

36 miscellaneous wells associated with oil and gas production were permitted in and around the 

37 Ross Project area. These include three wells within the Ross Project area itself (Nos. 

38 P50917W, P67746W and P67747W) that are currently used as water-supply wells for EOR 

39 operations (i.e., water flooding) (Strata, 2011a). In 1981, International Minerals & Chemical 

40 Corporation (IM&CC) permitted five pits (Nos. P58895W, P58896W, P58899W, P58902W and 

41 P58905W) for dewatering and dust suppression associated with bentonite mining. According to 

42 WSEO records, the water rights were cancelled prior to 2001 at the request of IM&CC. 

43

44 Between 1991 and 2009, the only ground-water rights that have been filed within the Ross 

45 Project and surrounding areas are for domestic and livestock use. In 2009, the Applicant

46 obtained ground-water rights for its pre-licensing baseline monitoring wells. The historical 

47 ground-water use within the Ross Project area is summarized in Table 3.9. 
DRAFT Affected Environment

3-45

Table 3.9

Historical Ground-Water Use within 

Three Kilometers [Two Miles] of Ross Project Area

Use

Number 

of Wells

Percent of 

Total Use

Appropriation 

Dates

Domestic Only 5 4 1943 – 1995

Domestic and Stock 15 13 1918 – 2003

Domestic, Stock, and 

Irrigation 1 <1 1972 – 1972

Stock Only 34 29 1933 – 2010

Stock and Irrigation 1 <1 1961 – 1961

Monitoring 39 33 1977 – 2010

Industrial or 

Miscellaneous 24 20 1977 – 1991

TOTAL 119 100 1918 – 2010

1 Source: Strata, 2011a.

2

3 Within the Ross Project area, ground-water use follows a similar pattern to that observed within 

4 the 3.2-km [2-mile] surrounding vicinity, except that historical use has been livestock only (no 

5 domestic or irrigation use). More recent uses include monitoring-well use as well as industrial 

6 uses associated with Nubeth and with water supply for oil and gas operations. Most of the 

7 ground-water rights represented in Table 3.9 have been cancelled or are no longer active. 

8 Current ground-water use is limited to four livestock wells, the Applicant’s regional pre-licensing 

9 baseline monitoring wells, and three industrial wells (i.e., water supply for oil and gas 

10 production). The stock wells are completed at total depths ranging from 39 – 81 m [128 – 265 

11 ft], which are considerably above the ore-zone aquifer. The currently operating, industrial water 

12 wells are completed at total depths of 163 – 229 m [536 – 750 ft]. Together, these wells 

13 withdraw an average of approximately 1.9 L/s [30 gal/s] from the ore-zone aquifer. 

14

15 3.6 Ecology

16

17 The Proposed Action is located within the Powder River Basin of the Northwest Great Plains 

18 ecoregion. As described in the GEIS, this area is characterized by rolling prairie and dissected 

19 river breaks surrounding the Powder, Cheyenne, and Upper North Platte Rivers (NRC, 2009b). 

20 Vegetation within this region is composed of sagebrush and mixed-grass prairie dominated by 

21 blue grama (Bouteloua gracilis), western wheatgrass (Pascopyrum smithii), needle-and-thread 

22 grass (Stipa comata), rabbitbrush (Chrysothamnus sp.), fringed sage (Artemisia frigida), and 

23 other forbs, shrubs, and grasses (NRC, 2009b).

24

25 The Applicant has conducted a number of ecological studies of the proposed Ross Project area 

26 to address the guidelines indicated in NUREG–1569, including the identification of important 

27 species and their relative abundance, and to meet the applicable Wyoming requirements (NRC, 

28 2003). These studies included vegetation and wildlife surveys conducted on the Ross Project 

29 area in late 2009 and 2010 (Strata, 2011a).
DRAFT Affected Environment

3-46

1 3.6.1 Terrestrial Species 2

3 3.6.1.1 Vegetation 4

5 The Applicant conducted pre-licensing baseline vegetation and wetland surveys during 2009 

6 and 2010, in accordance with State and Federal guidelines (Strata, 2011a). The spatial 

7 distribution of the vegetation types within the Ross Project area are shown in Figure 3.16. The 

8 vegetation mapped at the Ross Project area included upland grassland, sagebrush shrubland, 

9 pastureland, hayland, reservoir/stock pond, wetland, disturbed land, cropland, and wooded 

10 draw. No threatened or endangered plant species have been documented on the Ross Project 

11 area. 

12

13 Each vegetation community was investigated by the Applicant to establish a baseline in support 

14 of the Proposed Action. In terms of diversity, the sagebrush-shrubland vegetation type 

15 exhibited the highest total number of individual plant species recorded in 2010, followed by the 

16 upland-grassland and pasture-land vegetation types (see Table 3.10). 

17

18

Table 3.10

Species Diversity by Vegetation Type

at Ross Project Area

Species Type

Number of Individual Plant Species Recorded

Sagebrush 

Shrubland

Upland

Grassland Pastureland

Perennials

Grass 16 16 9

Grass-like 2 2 0

Forb 28 27 6

Subshrub 4 4 1

Full Shrub 5 1 1

Succulent 1 1 0

Subtotal 56 51 17

Annuals

Grass 2 2 0

Forb 7 3 1

Subtotal 9 5 1

TOTAL 65 56 18

19 Source: Strata, 2011a.
DRAFT Affected Environment

3-47

1

Figure 3.16

Baseline Vegetation at Ross Project Area

Source: Strata, 2012a.
DRAFT Affected Environment

3-48

1 Several species of designated and prohibited noxious weeds listed by the Wyoming Weed and 

2 Pest Control Act were identified on the Ross Project area. These species included field 

3 bindweed (Convolvulus arvensis), perennial sow thistle (Sonchus arvensis), quackgrass 

4 (Agropyron repens), Canada thistle (Cirsium arvense), houndstongue (Cynoglossum officinale), 

5 leafy spurge (Euphorbia esula), common burdock (Arctium minus), Scotch thistle (Onopordum 

6 acanthium), Russian olive (Eleagnus angustifolia), and skeletonleaf bursage (Ambrosia 

7 tomentosa). These weed species may be locally abundant in small areas, especially around the 

8 Oshoto Reservoir and along the Little Missouri River and Deadman Creek, but they were not 

9 common throughout the entire area of the Ross Project.

10

11 Selenium-indicator species identified on the Ross Project area in 2010 included two-grooved 

12 milkvetch (Astragalus bisulcatus), woody aster (Xylorhiza glabriuscula), and stemmy 

13 goldenweed (Haplopappus multicaulis); however, these indicator species were not abundant. 

14 Little larkspur (Delphinium bicolor), locoweed (Oxytropis sericea and Oxytropis lambertii), and 

15 meadow deathcamas (Zigadenus venenosus) are poisonous plants that were observed on the 

16 Ross Project area in limited numbers (locoweed is only poisonous for cattle). Cheatgrass 

17 (Bromus tectorum), although not a State-listed noxious weed, was abundant in some areas 

18 within the Ross Project area (Strata, 2011a).

19

20 3.6.1.2 Wildlife

21

22 Habitat Description

23

24 Background information on terrestrial vertebrate wildlife species in the vicinity of the Ross 

25 Project area was obtained from several sources, including records from the WGFD, BLM, and 

26 USFWS as well as from GEIS Section 4.4.5 (NRC, 2009b). Previous site-specific data for the 

27 Ross Project area and its surrounding environs were obtained from those same sources and 

28 Nubeth’s Environmental Report Supportive Information (ND Resources, 1977). In addition, the 

29 Applicant completed site-specific wildlife surveys from November 2009 through October 2010 to 

30 establish one year of baseline site-characterization data (Strata, 2011a). Over 140 different 

31 species were noted during these surveys or documented by other sources, e.g. WGFD (see 

32 Table 3.11). The surveys also focused on the Applicant obtaining information regarding bald 

33 eagles’ winter roosts; however, all nesting raptors, threatened and endangered species, the 

34 BLM’s Sensitive Species (BLMSS), and the USFWS’s “Migratory Bird Species of Management 

35 Concern in Wyoming” (SMC) (also known as “Migratory Birds of High Federal Interest”) were 

36 included in the survey procedures. Surveys were also conducted on the Ross Project area for 

37 swift fox, breeding birds, and northern leopard frogs. In addition to those species that were 

38 targeted, others were noted when observed. 

39

Table 3.11

Wildlife Species Observed on or near Ross Project Area

Scientific Name Common Name

Mammals

Sylvilagus audubonii Desert Cottontail

Lepus californicus Black-tailed Jackrabbit

Lepus townsendii White-tailed Jackrabbit
DRAFT Affected Environment

3-49

Table 3.11

Wildlife Species Observed on or near Ross Project Area (Cont.)

Scientific Name Common Name

Mammals (Continued)

Tamias minimus Least Chipmunk

Spermophilus tridecemlineatus Thirteen-lined Ground Squirrel

Cynomys ludovicianus Black-tailed Prairie Dog

Sciurus niger Eastern Fox Squirrel

Thomomys talpoides Northern Pocket Gopher

Dipodomys ordii Ord's Kangaroo Rat

Castor Canadensis Beaver

Peromyscus maniculatus Deer Mouse

Neotoma cinerea Bushy-tailed Woodrat

Microtus 0ochrogaster Prairie Vole

Ondatra zibethicus Muskrat

Erethizon dorsatum Porcupine

Canis latrans Coyote

Vulpes vulpes Red Fox

Procyon lotor Raccoon

Mustela frenata Long-tailed Weasel

Taxidea taxus Badger

Mephitis mephitis Striped Skunk 

Felis concolor Mountain Lion

Felis rufus Bobcat

Cervus elaphus American Elk

Odocoileus hemionus Mule Deer

Odocoileus virginianus White-tailed Deer

Antilocapra americana Pronghorn

Birds

Branta canadensis Canada Goose

Cygnus buccinator Trumpeter swan

Cygnus columbianus Tundra Swan

Anas strepera Gadwall

Anas americana American Wigeon

Anas platyrhynchos Mallard

Anas discors Blue-winged Teal

Anas crecca Green-winged Teal

Anas cyanoptera Cinnamon Teal

Anas clypeata Northern Shoveler

Anas acuta Northern Pintail

Aythya valisineria Canvasback

Aythya americana Redhead

Aythya collaris Ring-necked Duck

Aythya affinis Lesser Scaup
DRAFT Affected Environment

3-50

Table 3.11

Wildlife Species Observed on or near Ross Project Area (Cont.)

Scientific Name Common Name

Birds (Continued)

Bucephala albeola Bufflehead

Oxyura jamaicensis Ruddy Duck

Podilymbus podiceps Pied-billed Grebe

Podiceps auritus Horned Grebe

Podiceps nigricollis Eared Grebe

Pelecanus erythrorhynchos White Pelican

Phalacrocorax auritus Double-crested Cormorant

Ardea herodias Great Blue Heron

Cathartes aura Turkey Vulture

Pandion haliaetus Osprey

Haliaeetus leucocephalus Bald Eagle

Circus cyaneus Northern Harrier

Accipiter striatus Sharp-shinned Hawk

Accipiter cooperii Cooper's Hawk

Buteo swainson Swainson's Hawk

Buteo jamaicensis Red-tailed Hawk

Buteo regalis Ferruginous Hawk

Buteo lagopus Rough-legged Hawk

Aquila chrysaetos Golden Eagle

Falco sparverius American Kestrel

Falco mexicanus Prairie Falcon

Centrocercus urophasianus Greater Sage-grouse

Tympanuchus phasianellus Sharp-tailed grouse

Meleagris gallopavo Wild Turkey

Porzana carolina Sora Rail

Fulica americana American Coot

Charadrius vociferous Killdeer

Recurvirostra americana American Avocet

Actitis macularia Spotted Sandpiper

Bartramia longicauda Upland Sandpiper

Gallinago delicata Wilson’s Snipe

Phalaropus tricolor Wilson's Phalarope

Larus californicus California Gull

Larus argentatus Herring Gull

Chlidonias niger Black Tern

Columba livia Rock Pigeon

Zenaida macroura Mourning Dove

Bubo virginianus Great Horned Owl

Asio flammeus Short-eared Owl

Chordeiles minor Common Nighthawk

Ceryle alcyon Belted Kingfisher
DRAFT Affected Environment

3-51

Table 3.11

Wildlife Species Observed on or near Ross Project Area (Cont.)

Scientific Name Common Name

Birds (Continued)

Picoides villosus Hairy Woodpecker

Colaptes auratus Northern Flicker

Contopus sordidulus Western Wood-Pewee

Sayornis saya Say's Phoebe

Tyrannus verticalis Western Kingbird

Tyrannus tyrannus Eastern Kingbird

Eremophila alpestris Horned Lark

Tachyceneta bicolor Tree Swallow

Tachycineta thalassina Violet-green Swallow

Stelgidopteryx serripennis Northern Rough-winged Swallow

Riparia riparia Bank Swallow

Hirundo pyrrhonota Cliff Swallow

Hirundo rustica Barn Swallow

Cyanocitta cristata Blue jay

Pica pica Black-billed Magpie

Corvus brachyrhynchos American Crow

Corvus corax Common Raven

Parus atricapillus Black-capped Chickadee

Sitta canadensis Red-breasted Nuthatch

Salpinctes obsoletus Rock Wren

Troglodytes aedon House Wren

Sialia currucoides Mountain Bluebird

Turdus migratorius American Robin

Oreoscoptes montanus Sage Thrasher

Toxostoma rufum Brown Thrasher

Sturnus vulgaris European Starling

Lanius ludovicianus Loggerhead Shrike

Vermivora celata Orange-crowned Warbler

Dendroica petechia Yellow Warbler

Dendroica coronate Yellow-rumped Warbler

Geothlypis trichas Common Yellowthroat

Wilsonia pusilla Wilson's Warbler

Spizella passerine Chipping Sparrow

Spizella breweri Brewer's Sparrow

Pooecetes gramineus Vesper Sparrow

Chondestes grammacus Lark Sparrow

Calamospiza melanocorys Lark Bunting

Ammodramus savannarum Grasshopper Sparrow

Junco hyemalis Dark-eyed Junco

Calcarius mccownii McCown's Longspur

Agelaius phoeniceus Red-winged Blackbird
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Table 3.11

Wildlife Species Observed on or near Ross Project Area (Cont.)

Scientific Name Common Name

Birds (Continued)

Sturnella neglecta Western Meadowlark

Xanthocephalus xanthocephalus Yellow-headed Blackbird

Euphagus cyanocephalus Brewer's Blackbird

Quiscalus quiscula Common Grackle

Molothrus ater Brown-headed Cowbird

Icterus bullockii Bullock's Oriole

Carpodacus mexicanus House Finch

Carduelis pinus Pine Siskin

Passer domesticus House Sparrow

Amphibians

Ambystoma tigrinum Tiger Salamander

Pseudaris triseriata maculate Boreal Chorus Frog

Rana pipiens Northern Leopard Frog

Reptiles

Phrynosoma douglassi brevirostre Eastern Short-horned Lizard

Sceloporus graciosus graciosus Northern Sagebrush Lizard

Chelydra serpentina serpentina Common Snapping Turtle

Chrysemys picta belli Western Painted Turtle

Crotalus viridis viridis Prairie Rattlesnake

Pituophis melanoleucas sayi Bullsnake

Thamnophis elegans vagrans Wandering Garter Snake

Fish

Ameiurus melas Black Bullhead

Lepomis cyanellus Green Sunfish

Lepomis macrochirus Bluegill

Catastomus commersoni White Sucker

1 Source: Strata, 2011a.

2

3 Mammals

4

5 Pronghorn antelope (Antilocapra americana), mule deer (Odocoileus hemionus), and white6 tailed deer (O. virginianus) were the only big-game species that were observed on the Ross 

7 Project area during the 2009 and 2010 surveys (Strata, 2011a). American elk (Cervus elaphus) 

8 have been recorded in the area by the WGFD; however, none were observed during the

9 Applicant’s surveys. No crucial big-game habitats or migration corridors are recognized by the 

10 WGFD at the Ross Project or the surrounding 1.6-km [1-mi] vicinity. 

11

12 Pronghorn antelope and mule deer are common but not abundant on the Ross Project area. 

13 Pronghorn herds were most often observed in sagebrush-shrubland and upland-grassland 

14 habitats, and the mule deer frequented the sagebrush-shrubland habitat (Strata, 2011a). Both 
DRAFT Affected Environment

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1 species used haylands and cultivated fields in the area. White-tailed deer were not abundant, 

2 but they were observed in the riparian habitats and on the cultivated fields within and near the 

3 Ross Project area. Pronghorn antelopes’ use of the Ross Project and surrounding areas has 

4 been classified by the WGFD as year long, and mule deer use within the areas as winter and 

5 year long. White-tailed deer and elk use has been classified by the WGFD as out of their 

6 normal range. The Ross Project is located within the WGFD North Black Hills pronghorn-herd 

7 unit, the Powder River and Black Hills mule deer-herd units, and the Thunder Basin and Black 

8 Hills white-tailed deer-herd units. The Ross Project area is not within a specific elk-herd unit, 

9 but it is included in the WGFD designated area referred to as “Hunt Area 129” (Strata, 2011a).

10

11 A variety of small- and medium-sized mammals could potentially be present on the Ross Project 

12 area. These mammals include a variety of predators and furbearers, such as coyote (Canis 

13 latrans), red fox (Vulpes vulpes), raccoon (Procyon lotor), bobcat (Lynx rufus), badger (Taxidea 

14 taxus), beaver (Castor canadensis), and muskrat (Ondatra zibethicus). Prey species that were 

15 observed included rodents (e.g., mice, rats, voles, gophers, ground squirrels, chipmunks, prairie 

16 dogs), jackrabbits (Lepus spp.), and cottontails (Sylvilagus spp.). These species are cyclically 

17 common and widespread throughout the vicinity, and they are important food sources for 

18 raptors and other predators. Each of these prey species was either directly observed during 

19 Strata’s field surveys or was known to exist through the presence of burrow formation or of 

20 droppings. Jackrabbit and cottontail sightings were common.

21

22 While black-tailed prairie dogs (Cynomys ludovicianus) are listed as occurring in the general 

23 area of the Ross Project, no black-tailed prairie-dog colonies (important as habitat for black24 footed ferrets) were located within the 1.6-km [1-mi] survey area. Other mammal species, such 

25 as the striped skunk (Mephitis mephitis), porcupine (Erethizon dorsatum), and various weasels 

26 (Mustela spp.) inhabit sagebrush grassland and riparian communities, and these species were 

27 recorded within the Ross Project area during the Applicant’s wildlife surveys. No bat species 

28 were observed during the baseline surveys. There are no records of prior use of the Ross 

29 Project by swift fox (Vulpes velox), and none were observed during the 2009 or 2010 surveys.

30

31 Birds

32

33 Suitable habitat for several raptor species occurs at the Ross Project area and within the 1.6-km 

34 [1-mi] vicinity surrounding it. Several raptor species were observed during the wildlife surveys; 

35 these included the bald eagle, red-tailed hawk (Buteo jamaicensis), golden eagle (Aquila 

36 chrysaetos), ferruginous hawk (Buteo regalis), Swainson’s hawk (Buteo swainsoni), northern 

37 harrier (Circus cyaneus), American kestrel (Falco sparverius), Cooper's hawk (Accipiter 

38 cooperii), Sharp-shinned hawk (Accipiter striatus), rough-legged hawk (Buteo lagopus), great 

39 horned owl (Bubo virginianus), and short-eared owl (Asio flammeus). Turkey vultures 

40 (Cathartes aura) and prairie falcons (Falco mexicanus) have also been recorded on the Ross 

41 Project area, but they were not seen during the Applicant’s surveys.

42

43 In the vicinity of the Ross Project area, nests were observed for the ferruginous, red-tailed, and 

44 Swainson’s hawks (Strata, 2011a). The only nest observed within the Project area itself was a 

45 Swainson’s hawk’s nest, which was observed to be inactive during the 2010 survey year. A 

46 total of seven intact nesting sites were observed within 1.6 km [1 mi] of the Ross Project area.

47

48 The wild turkey (Meleagris gallopavo), Greater sage-grouse (Centrocercus urophasianus), 

49 sharp-tailed grouse (Tympanuchus phasianellus), and mourning dove (Zenaida macroura) were 
DRAFT Affected Environment

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1 observed at the Ross Project area by the Applicant. Mourning doves were recorded during the 

2 spring and summer months. 

3

4 The Greater sage-grouse (Centrocercus urophasianus) is listed as a Federal candidate species 

5 and a Wyoming Species of Concern (WSOC) in Wyoming (75 FR 13090; WGFD, 2005a) (see 

6 SEIS Section 3.6.1.4, below). Potential sage-grouse habitat is present at the Ross Project area 

7 (upland grassland, sagebrush shrubland, pastureland, hayland, and reservoir/stock pond). Two 

8 leks, which is where male sage grouse congregate for competitive mating displays, have been 

9 recorded within several miles of the Ross Project. Leks assemble before and during the 

10 breeding season on a daily basis; the same group of males meet at traditional locations each 

11 season. However, the Ross Project area is not located in a region currently designated as a 

12 sage-grouse core area. 

13

14 Breeding-bird surveys were conducted within the Ross Project area in four habitat types: upland 

15 grassland, sagebrush shrubland, pastureland/hayland, and wetland/reservoir. Twenty-seven 

16 species were recorded during the 2010 breeding-bird surveys. The Wetland/Reservoir habitat 

17 produced the greatest species diversity, with 19 species observed. The upland grassland 

18 habitat had the fewest species, with six species observed. 

19

20 Natural aquatic habitats on the Ross Project occur at the Oshoto Reservoir and along the Little 

21 Missouri River. During the Applicant’s wildlife surveys, 17 waterfowl and 8 shorebird species 

22 were observed. In these categories, the horned grebe (Podilymbus podiceps) and upland 

23 sandpiper (Bartramia longicauda) are the only USFWS’s SMC observed within or near the Ross 

24 Project area.

25

26 3.6.1.3 Reptiles, Amphibians, and Aquatic Species

27

28 During the Applicant’s baseline wildlife surveys in 2009 and 2010, the eastern short-horned 

29 lizard (Phrynosoma douglassi brevirostre) and northern sagebrush lizard (Sceloporus graciosus 

30 graciosus) were often observed. Other reptiles observed in the area included the bullsnake 

31 (Pituophis cantenifer), wandering garter snake (Thamnophis elegans vagrans), and the prairie 

32 rattlesnake (Crotalus viridis viridis).

33

34 Water is a limiting factor for wildlife on the Ross Project area, where only one stream flows 

35 occasionally; the Oshoto Reservoir is the major water feature within the Ross Project area. All 

36 other natural drainages are categorized as intermittent or ephemeral (see SEIS Section 3.5.1). 

37 The lack of deep-water habitat and perennial water sources decreases the potential for many 

38 aquatic species to exist. Three aquatic or semi-aquatic amphibian species and two aquatic 

39 reptiles were recorded during the Applicant’s baseline surveys: the tiger salamander 

40 (Ambystoma tigrinum), boreal chorus frog (Pseudacris triseriata), northern leopard frog (Rana 

41 pipiens), common snapping turtle (Chelydra serpentine), and western painted turtle (Chrysemys 

42 picta). All five species were heard and/or seen in the Oshoto Reservoir, Little Missouri River, or 

43 near stock reservoirs. All five species are common to the Ross Project and the vicinity as a 

44 whole. No egg masses were identified during the egg-mass surveys completed in early June 

45 2010. The reason for their absence could have been that recent high winds could have broken 

46 up the egg masses and dispersed the individual eggs. During walking surveys along shorelines 

47 and riparian areas in August 2010, the leopard frog appeared to be quite common—over 500 

48 individual adults were counted—while the chorus frog was uncommon. 
DRAFT Affected Environment

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1 The Applicant also conducted fish sampling from the Oshoto Reservoir in September 2010, 

2 under a WGFD Chapter 33 collection permit, as part of its establishing pre-licensing baseline 

3 radiological conditions for the Ross Project. The dominant fish population in the Oshoto 

4 Reservoir included black bullheads (Ameiurus melas) and green sunfish (Lepomis cyanellus); 

5 white suckers (Catastomus commeroni) and bluegill (Lepomis macrochirus) were also present. 

6 The sample fish from this population were stunted in size for their ages; high reproductive rates 

7 and limited predation leads to over-population and stunted growth. The Oshoto Reservoir and 

8 the other water bodies within the Ross Project area are not considered viable sport fisheries 

9 (see SEIS Section 3.2.2). 

10

11 3.6.1.4 Protected Species

12

13 The Ute ladies’-tresses orchid (Spiranthes diluvialis) is Federally-listed as threatened. The 

14 species is a perennial, terrestrial orchid that occurs in Colorado, Idaho, Montana, Nebraska, 

15 Utah, Washington, and Wyoming. Within Wyoming, this orchid inhabits moist meadows with 

16 moderately dense but short vegetative cover. As noted in Fertig (2000), this species is found at 

17 elevations of 1,280 – 2,130 m [4,200 – 7,000 ft], though no known populations occur in 

18 Wyoming above 1,680 m [5,500 ft]. This species was not located during the Applicant’s 

19 vegetation surveys, and it is not known to occur on or in the vicinity of the Ross Project area.

20

21 The blowout penstemon (Penstemon haydenii) is Federally listed as endangered, although it is 

22 not included on the list for Crook County. However, it is on the list for neighboring Campbell 

23 County, and the Applicant therefore evaluated the potential for the blowout penstemon to occur 

24 in the Ross Project area. This species is found exclusively in sparsely vegetated, early 

25 successional sand dunes or blowout areas at elevations of 1,786 – 2,268 m [5,860 – 7,440 ft] 

26 (Fertig, 2008). The Ross Project does not have sand-dune habitat, and it is outside of the 

27 elevation range in which this species is typically found. This species was not identified during 

28 Strata’s vegetation surveys; appropriate habitat was not identified; and it is not known to occur 

29 on or in the vicinity of the Ross Project. 

30

31 The black-footed ferret (Mustela nigripes) is a Federally listed endangered species, which 

32 inhabits prairie-dog colonies. A black-footed ferret survey was not required by USFWS 

33 requirements, because black-footed ferrets live exclusively in prairie-dog colonies, which are not 

34 present on or within 1.6 km [1 mi] of the Ross Project area (Strata, 2011a). 

35

36 The bald eagle (Haliaeetus leucocephalus) was delisted from Federal threatened status in 2007, 

37 but it is still protected under the Bald and Golden Eagle Protection Act and the Migratory Bird 

38 Treaty Act. Potential habitat for bald eagle nesting and roosting activities is quite limited within 

39 the Ross Project because of the lack of trees. Bald eagles were observed from the Ross 

40 Project area during wildlife surveys that took place November and December of 2009 and 

41 January through September of 2010 (Strata, 2011a). No nests were observed, however, and 

42 the bald eagle is considered to be a winter migrant to the area.

43

44 The Greater sage-grouse (Centrocercus urophasianus) is Federally listed as a Candidate 

45 species, as a State of Wyoming’s Species of Concern (WSOC), and as a BLMSS. On March 5, 

46 2010, the USFWS published a finding in the FR stating that listing of the species was warranted 

47 but precluded by higher priority listing actions (75 FR 13909). The Governor of Wyoming issued 

48 Executive Order (EO) 2010-4 in August 2010 which sets out 12 provisions for oil- and gas49 resource operations within core and noncore population areas to protect the species at the 
DRAFT Affected Environment

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1 State level (State of Wyoming, 2011). The WGFD published Recommendations for 

2 Development of Oil and Gas Resources Within Important Wildlife Habitats and the Wyoming 

3 Field Office of the BLM issued an instructional memorandum on March 5, 2010, which 

4 supplements the BLM’s 2004 National Sage-Grouse Habitat Conservation Strategy, to be 

5 consistent with the Governor’s Executive Order (EO) (WGFD, 2010; BLM, 2004; BLM, 2010a). 

6 The WGFD guidance was again updated in April 2010. 

7

8 The Greater sage-grouse inhabits open sagebrush plains in the western U.S. and is found at 

9 elevations of 1,200 – 2,700 m [3,937 – 8,858 ft], corresponding with the occurrence of 

10 sagebrush habitat (69 FR 933). The Greater sage-grouse is a mottled brown, black, and white 

11 ground-dwelling bird that can be up to 0.6 m [2 ft] tall and 76 cm [30 in] in length (69 FR 933). 

12 Breeding habitat, referred to as leks (see SEIS Section 3.6.1.2), and stands of sagebrush 

13 surrounding leks are used by sage-grouse in early spring and are particularly important habitat 

14 because the birds often return to the same leks and nesting areas each year. Leks are 

15 generally more sparsely vegetated areas such as ridgelines or disturbed areas adjacent to 

16 stands of sagebrush habitat. 

17

18 Two sage-grouse leks are known to occur within 3 km [2 mi] of the Ross Project area. The 

19 Oshoto Lek (Sections 28 and 29, T53N, 67W) and the Cap’n Bob Lek (Section 32, T53 N, 

20 R67W) have been identified; no other sage-grouse leks were identified during the wildlife 

21 surveys. Details of sage-grouse mating activities for these leks are summarized in Table 3.12. 

22 A ground survey of the Oshoto and Cap’n Bob leks were conducted by the Applicant on two 

23 days in April 2010. On the Cap’n Bob lek, a total of two males and one female were observed 

24 on one day, and two males were observed on the second day; no sage-grouse were observed 

25 at the Oshoto Lek during the survey. No broods or brood-rearing areas were identified during 

26 the Applicant’s 2010 survey. In addition, no sage-grouse wintering areas were identified on the 

27 Ross Project area (Strata, 2011a).

28

29 Threats to this species’ survival include habitat loss, agricultural practices, livestock grazing, 

30 hunting, and land disturbances from energy and mineral development as well as the oil and gas 

31 industry (Sage-Grouse Working Group, 2006). Although the two leks described earlier were 

32 recorded near the Ross Project, the Project area is not located within a designated sage-grouse 

33 core area. Additionally, although sharp-tailed grouse were observed on the Ross Project area 

34 during only the 2009 winter survey, they are considered year-long residents of the Project area.
DRAFT Affected Environment

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1

2

Table 3.12

Summary of Sage-Grouse Activity

in Oshoto and Cap’n Bob Leks

Year of

Survey 

Activity

Oshoto Cap’n Bob

1985 6 males No information

1988 0 ′′

1988 0 ′′

1991 0 ′′

1994 0 ′′

1997 0 ′′

2000 0 ′′

2001 5 males ′′

2004 2 males ′′

2007 0 10 males

2007 0 10 males

2010 0 2 males

1 female

2010 0 2 males

3 Source: Strata, 2011a.

4

5 The mountain plover (Charadrius montanus) is Federally proposed as threatened and is a 

6 Wyoming Species of Greatest Conservation Need. The species is a small bird approximately 

7 17.8 cm [7 in] in height with light brown and white coloring. The mountain plover is a native of 

8 the short-grass prairie and is found in open, dry shrubland, or agricultural fields with short 

9 vegetation and bare ground. Prairie dogs and other burrowing animals provide highly suitable 

10 habitat for the mountain plover. 

11

12 Mountain plover breeding habitat includes the western Great Plains and Rocky Mountain 

13 states extending from the Canadian border to northern Mexico (75 FR 37353). The prime 

14 breeding and nesting period for the mountain plover is from April 10 through July 10 (BLM, 

15 2007a). In Wyoming, the greatest concentration of mountain plovers is found in the south 

16 central part of the state, but they can be found in every county (Andres 2009; UW, 2010). 

17 This bird is often found in areas with heavy grazing and landscapes with excessive surface 

18 disturbance. USFWS originally proposed this species as threatened on February 16, 1999 

19 (64 FR 7587); the proposal was withdrawn on September 9, 2003, but it was reinstated on 

20 June 29, 2010 (68 FR 53083; 75 FR 37353). This species was not observed during either the 

21 2009 or 2010 wildlife surveys (Strata, 2011a). 

22

23 Table 3.13 lists species that occur in Crook County and that are Federally listed under the 

24 Endangered Species Act (ESA), State-listed under the Final Comprehensive Wildlife 

25 Conservation Strategy for Wyoming, or are listed as a BLMSS.
DRAFT Affected Environment

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1

Table 3.13

Species of Concern in Crook County and at Ross Project Area

Common Name Scientific 

Name

USFWS 

Species of 

Management 

Concern (Level)1

BLM 

Sensitive 

Species

Wyoming 

Species of 

Concern 

Status2

Observed on 

the Ross 

Project Area

Mammals

Hayden’s Shrew

Sorex haydeni NSS4*

Vagrant Shrew 

Sorex vagrans NSS3*

Long-eared Myotis 

Myotis evotis Yes NSS2*

Northern Myotis 

Myotis septentrionalis NSS2*

Little Brown Myotis 

Myotis lucifugus NSS3*

Long-legged Myotis 

Myotis volans NSS2*

Fringed myotis 

Myotis thysanodes Yes NSS2*

Hoary Bat 

Lasiurus cinereus NSS4*

Silver-haired Bat 

Lasionycteris noctivagans NSS4*

Big Brown Bat 

Eptesicus fuscus NSS3*

Black-tailed Prairie Dog 

Cynomys ludovicianus NSS3* Yes

Plains Pocket Gopher

Geomys bursarius NSS4*

Olive-backed Pocket Mouse

Perognathus fasciatus NSS3*

Silky Pocket Mouse

Perognathus flavus NSS3*

Western Harvest Mouse

Reithrodontomys megalotis NSS3*

Prairie Vole

Microtus ochrogaster NSS3* Yes

Sagebrush Vole

Lemmiscus curtatus NSS4*

Swift Fox

Vulpes velox Yes NSS4*
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Table 3.13

Species of Concern in Crook County and on the Ross Project Area

(Continued)

Common Name Scientific 

Name

USFWS 

Species of 

Management 

Concern (Level)1

BLM 

Sensitive 

Species

Wyoming 

Species of 

Concern 

Status2

Observed on 

the Ross 

Project Area

Mammals (Continued)

Black-footed Ferret

Mustela nigripes NSS1*

Birds

Waterfowl and Shorebirds

Trumpeter swan

Cygnus buccinator Yes NSS2 Yes

Northern Pintail 

Anas acuta NSS3 Yes

Canvasback

Aythya valisineria NSS3 Yes

Redhead

Aythya americana NSS3 Yes

Lesser Scaup

Aythya affinis NSS3 Yes

Horned Grebe

Podiceps auritus Yes (NL) Yes

Western Grebe 

Aechmophorus occidentalis NSS4

American Bittern 

Botauosus lentiginosus Yes (I) NSS3

Great Blue Heron

Ardea herodias NSS4 Yes

Black-crowned Night-Heron

Nycticorax nycticorax NSS3

White-faced Ibis

Plegadis chihi Yes NSS3

Sandhill Crane

Grus canadensis NSS3

Mountain Plover

Charadrius montanus Yes (I) Yes NSS4*

Upland Sandpiper

Bartramia longicauda Yes (I) NSS4 Yes

Marbled Godwit

Limosa fedoa Yes (NL)

Long-billed Curlew

Numenius americanus Yes (I) Yes NSS3*

1
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Table 3.13

Species of Concern in Crook County and on the Ross Project Area

(Continued)

Common Name Scientific 

Name

USFWS 

Species of 

Management 

Concern (Level)1

BLM 

Sensitive 

Species

Wyoming 

Species of 

Concern 

Status2

Observed on 

the Ross 

Project Area

Raptors

Bald Eagle

Haliaeetus leucocephalus Yes (I) NSS2 Yes

Northern Goshawk

Accipiter gentilis Yes NSS4*

Swainson's Hawk

Buteo swainsoni NSS4 Yes

Ferruginous Hawk

Buteo regalis Yes (I) Yes NSS3* Yes

Golden Eagle

Aquila chrysaetos Yes (III) Yes

Merlin

Falco columbarius NSS3*

Peregrine Falcon

Falco peregrinus Yes (I) NSS3*

Prairie Falcon

Falco mexicanus Yes (III) Yes

Burrowing Owl

Athene cunicularia Yes (I) Yes NSS4

Short-eared Owl

Asio flammeus Yes (I) NSS4 Yes

Upland Game

Greater Sage-grouse

Centrocercus urophasianus Yes NSS2 Yes

Other

White Pelican 

Pelecanus erythrorhynchos NSS3 Yes

Franklin's Gull

Larus pipixcan NSS3

Forster's Tern

Sterna forsteri NSS3

Black Tern

Chlidonias niger NSS3 Yes

Black-billed Cuckoo 

Coccyzus erythropthalmus Yes (II)

Yellow-billed Cuckoo

Coccyzus americanus Yes (II) Yes NSS2*
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Table 3.13

Species of Concern in Crook County and on the Ross Project Area

(Continued)

Common Name Scientific 

Name

USFWS 

Species of 

Management 

Concern (Level)1

BLM 

Sensitive 

Species

Wyoming 

Species of 

Concern 

Status2

Observed on 

the Ross 

Project Area

Other (Continued)

Lewis’s Woodpecker 

Melanerpes lewis Yes (II) NSS3*

Willow Flycatcher

Empidonax traillii Yes (II) NSS3

Pinyon Jay 

Gymnorhinus cyanocephalus Yes (IV)

Pygmy Nuthatch

Sitta pygmaea NSS4*

Sage Thrasher

Oreoscoptes montanus Yes (II) Yes NSS4* Yes

Loggerhead Shrike 

Lanius ludovicianus Yes (II) Yes Yes

Dickcissel

Spiza americana Yes (II) NSS4

Brewer's Sparrow

Spizella breweri Yes (I) Yes NSS4 Yes

Sage Sparrow 

Amphispoza belli Yes (I) Yes NSS4

Lark Bunting

Calamospiza melanocorys Yes (II) NSS4 Yes

Baird's Sparrow

Ammodramus bairdii Yes (I) Yes

Grasshopper Sparrow

Ammodramus savannarum Yes (II) NSS4 Yes

McCown's Longspur

Calcarius mccownii Yes (I) NSS4 Yes

Chestnut-collared Longspur

Calcarius ornatus NSS4

Bobolink

Dolichonyz oryzivorus NSS4

Cassin's Finch

Carpodacus cassinii Yes (IV)

Amphibians

Tiger Salamander

Ambystoma tigrinum NSS4* Yes

Plains Spadefoot

Scaphiopus bombifrons NSS4*
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Table 3.13

Species of Concern in Crook County and on the Ross Project Area

(Continued)

Common Name Scientific 

Name

USFWS 

Species of 

Management 

Concern (Level)1

BLM 

Sensitive 

Species

Wyoming 

Species of 

Concern 

Status2

Observed on 

the Ross 

Project Area

Amphibians (Continued)

Great Plains Toad

Bufo cognatus NSS4*

Boreal Chorus Frog

Pseudaris triseriata maculate NSS4* Yes

Bullfrog

Rana catesbeiana NSS4*

Northern Leopard Frog

Rana pipiens Yes NSS4* Yes

Reptiles

Northern Sagebrush Lizard

Sceloporus graciosus 

graciosus

NSS4* Yes

Western Painted Turtle 

Chrysemys picta belli NSS4* Yes

Prairie Rattlesnake

Crotalus viridis viridis NSS3* Yes

Plains Hognose Snake

Heterondon nasicus nasicus NSS4*

Bullsnake

Pituophis melanoleucas sayi NSS4*

Wandering Garter Snake

Thamnophis elegans 

vagrans

NSS4*

Eastern Yellowbelly Racer

Coluber constrictor 

flaviventris

NSS4*

1 Source: Strata, 2011a.

2 Notes: See next page.
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1 Notes for Table 3.13::

 1 2 USFWS Level:

3  Level I (Conservation Action): Species clearly needs conservation action.

4  Level II (Monitoring): The action and focus for the species is monitoring (M). 

5 Declining population trends and habitat loss are not significant at this point.

6  Level III (Local Interest): Species that Wyoming Partners In Flight may recommend for conservation 

7 action that are not otherwise high priority but are of local interest (LI). 

8  Level IV (Not Considered Priority): Additional species of concern, but not considered a priority species. 2 9 WGFD Status:

10  NSS1: 1996 Nongame Bird and Mammal Plan Species of Special Concern 

11 with a Native Species Status of 1. 

12  NSS2: 1996 Nongame Bird and Mammal Plan Species of Special Concern 

13 with a Native Species Status of 2. 

14  NSS3: 1996 Nongame Bird and Mammal Plan Species of Special Concern 

15 with a Native Species Status of 3. 

16  NSS4: 1996 Nongame Bird and Mammal Plan Species of Special Concern 

17 with a Native Species Status of 4. 

18 *Species listed wholly or in part due to absence of data. 

19

20 The Wyoming Field Office of the USFWS also uses the SMC list for conducting reviews related 

21 to non-coal, surface-disturbance projects. Thirty-two birds on the WSOC list were identified on 

22 this list for the Ross Project area (see Table 3.13). Surveys for avian WSOC, including sage23 grouse, bald eagle, and mountain plovers, were conducted in 2009 and 2010 for the Ross 

24 Project area. Table 3.14 lists the avian WSOCs that were observed on the Ross Project area 

25 during the Applicant’s 2009 and 2010 baseline surveys (Strata, 2011a), including their primary 

26 nesting habitats and historical occurrence in the general Ross Project vicinity. 

27

28 In addition to the species previously discussed above, 20 bird species on the U.S. Fish and 

29 Wildlife Service’s (USFWS’s) SMC list could potentially be present within the Ross Project area. 

30 Of these 20 bird species, 7 have been observed within or near the Ross Project (see Table 

31 3.13). Ten non-raptor or non-game bird species on the BLMSS list could potentially occur within 

32 the Ross Project. Of the ten bird species, four have been observed on or near the Ross Project 

33 area (see Table 3.14). Thirty-two non-raptor or non-game bird species on the WSOC list could 

34 potentially be present within the Ross Project area. Of the 32 bird species, 15 have been 

35 actually observed on or near the Project area (see Tables 3.13 and 3.14). 
DRAFT Affected Environment

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1

Table 3.14

Avian Species of Concern Observed at Ross Project Area

Common Name

Scientific Name

Primary Nesting 

Habitat(s)1 Status2

Level 1 Species of Concern/Conservation Needed

Bald Eagle

Haliaeetus 

leucocephalus

Montane Riparian, 

Plains/Basin Riparian

Uncommon year-long

resident

Ferruginous Hawk

Buteo regalis

Shrub Steppe and 

Short-Grass Prairie

Summer uncommon

resident

Upland Sandpiper

Bartramia longicauda Short-Grass Prairie Summer uncommon

resident

Short-eared Owl

Asio flammeus

Short-grass Prairie and 

Meadows Common year-long resident

Brewer's Sparrow

Spizella breweri

Shrub Steppe and 

Mountain-Foothills Shrub Common summer resident

McCown's Longspur

Calcarius mccownii

Shrub steppe and 

short-grass prairie Common summer resident

Level 2 Species of Concern/Continued Monitoring Recommended

Sage Thrasher

Oreoscoptes montanus Shrub Steppe Common summer resident

Loggerhead Shrike 

Lanius ludovicianus Shrub Steppe Common summer resident

Lark Bunting

Calamospiza 

melanocorys

Shrub Steppe and 

Short-Grass Prairie Abundant summer resident

Grasshopper Sparrow

Ammodramus 

savannarum

Shrub Steppe and 

Short-Grass Prairie Common summer resident

Level 3 Species of Concern/Species of Local Interest

Golden Eagle

Aquila chrysaetos Specialized (Cliffs) Common year-long resident

Prairie Falcon 

Falco mexicanus Specialized (Cliffs) Common year-long resident

2 Sources: USFWS, 2011, and USGS, 2011.

3

4 3.7 Meteorology, Climatology, and Air Quality

5

6 3.7.1 Meteorology

7

8 The region of the Ross Project area is characterized by hot summers and cold winters, and 

9 rapid temperature fluctuations are common. The Rocky Mountains (the “Rockies”) have a great 

10 influence on the climate. As air crosses the Rockies from the west, much moisture is lost on the 
DRAFT Affected Environment

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1 windward sides of the Mountains, and the air becomes warmer as it descends on the eastern 

2 slopes (NRC, 2009b). The Ross Project area is located in this semi-arid area (Strata, 2011a). 

3

4 The closest National Weather Service (NWS) station with a long recording period is Gillette 

5 Airport, which is located 56 km [35 mi] southwest of the Ross Project (Strata, 2011a). As the 

6 GEIS noted, there is a NWS station in Crook County, at Colony, Wyoming (72 km [45 mi] 

7 northeast of the Ross Project) (NRC, 2009b). This station, however, ceased operation in 2008. 

8 In addition, the Applicant has installed a site-specific meteorology station in 2010, where 

9 meteorology data has been collected every month since the station went online (Strata, 2011a). 

10

11 Temperature

12

13 As described in the GEIS, the northwest Great Plains region has summer nights that are 

14 normally cool, even though daytime temperatures can be very warm. Winters can be quite cold; 

15 however, warm spells during winter months are common. The average temperatures for the 

16 two NWS stations in the vicinity of the Ross Project area, Colony and Gillette Airport, are shown 

17 in Table 3.15, in addition to the information collected by the Applicant in 2010 (NRC, 2009b; 

18 NWS, 2011; Strata, 2011a). 

19

Table 3.15

Average, Minimum, and Maximum Temperatures in Ross Project Vicinity

Station

Average 

Temperature

°C [°F]

Average Minimum 

Temperature

°C [°F]

Average Maximum 

Temperature

°C [°F]

Ross Project1 8.9 [48] - 4.3 [24.3] 23.9 [75]

Gillette Airport2 8.1 [46.5] N/A N/A

Colony3 8.3 [47] - 5.3 [22.5] 22.4 [72.3]

20 Source: Strata, 2011a; NRC, 2009b; NWS, 2011.

21 Notes: N/A = Data not available.

22 1 = Monitoring period 2010

23 2 = Monitoring period 1902 – 2009

24 3 = Monitoring period 1971 – 2000

25

26 At the Gillette Airport station, the warmest month of the year is July, with an average 

27 temperature of 23.6 °C [74.5 °F] (Strata, 2011a). The coldest month is December, with an 

28 average temperature of -4.7 °C [23.6 °F]. This trend was also observed at the Ross Project’s 

29 meteorology station, with an average July temperature of 23.1 °C [73.6 °F] and an average 

30 December temperature of -4.7 °C [23 °F] for 2010.

31

32 Wind

33

34 The average wind speed at the Gillette Airport station is 16.9 km/hr [10.5 mi/hr], with an average 

35 maximum wind speed from 2000 – 2009 of 77 km/hr [48 mi/hr] (Strata, 2011a). The highest 

36 winds were recorded in January through March, with the lowest speeds from July through 

37 September. As shown on the wind rose for the Ross Project area, the prevailing wind direction 

38 in the fall and winter is north/northwest (as shown in Figure 3.17), whereas in the spring and 
DRAFT Affected Environment

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1 summer, the winds are generally from the southeast. The highest wind speeds tend to occur 

2 from the north-northwest. 

3

4 During the 12 months of monitoring at the Applicant’s meteorology station in 2010, the average 

5 annual wind speed was 18.5 km/hr [11.5 mi/hr], ranging from a minimum wind speed of 0 km/hr 

6 [0 mi/hr] to a maximum wind speed of 73.4 km/hr [45.6 mi/hr]. More southerly winds were 

7 recorded at the Ross Project than at the Gillette Airport station (as shown in Figure 3.18); 

8 however, as at Gillette Airport, the highest wind speeds are from the northwest. 

9

10 Precipitation

11

12 The Ross Project area and the surrounding area receive relatively little rainfall, with average 

13 annual precipitation ranging from 25 – 38 cm [10 – 15 in]. The region receives an average 

14 annual snowfall of 127 – 152 cm [50 – 60 in]. At the Gillette Airport station, between 2005 –

15 2009, the average annual precipitation was measured at 30.5 cm [12 in] (Strata, 2011a). 

16 Approximately one-half of the precipitation is associated with spring snows and thunderstorms. 

17 May is the wettest month, with more than 5 cm [2 in] of precipitation, while January is the driest 

18 month, with average precipitation of approximately 1.3 cm [0.5 in] or less (Strata, 2011a).

19

20

21

22

23 At the Applicant’s onsite meteorology station, the total precipitation measured in 2010 was 24.8 

24 cm [9.8 in], compared to 32.5 cm [12.8 in] for the same period at the Gillette Airport station 

25 (Strata, 2011a). The difference in precipitation during 2010 was primarily due to the fact that 

26 Gillette Airport received 6.4 cm [2.5 in] more in the month of May than the Ross Project. 

27 Otherwise, the monthly precipitation data are very similar. 

28

Figures 3.17 and 3.18

Gillette Airport Wind Rose (Left)

Ross Project Area Wind Rose (Right)

Source: Strata, 2012a.
DRAFT Affected Environment

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1 Evaporation

2

3 As with the majority of the western U.S., the evaporation rate in northeastern Wyoming exceeds 

4 the rate of precipitation. As discussed in the GEIS, evaporation rates in the region range from 

5 102 – 127 cm/yr [40 – 50 in/yr] (NRC, 2009b). An evaporation pan was installed at the Ross 

6 Project’s meteorology station in June 2010; however, data are available from only June through 

7 late October 2010, because the gauge was removed to prevent its freezing. At the Gillette 

8 Airport station, evaporation in 2010 varied from slightly more than 10 cm [4 in] in April to almost 

9 25 cm [10 in] in July and August. For the period of time the evaporation pan operated at the 

10 Ross Project, similar rates were observed (Strata, 2011a). 

11

12 Atmospheric Stability Classification and Mixing Height

13

14 Atmospheric stability classification and mixing height are environmental variables that influence 

15 the ability of the atmosphere to disperse air pollutants. The stability class is a measure of 

16 atmospheric turbulence, and mixing height characterizes the vertical extent of contaminants 

17 mixing in the atmosphere. The nearest upper-air data available from the NWS are from Rapid 

18 City, South Dakota, approximately 170 km [106 mi] southeast of the Ross Project (Strata, 

19 2011a). However, Rapid City is approximately 1,700 m [5,577 ft] lower in elevation than the 

20 Ross Project, and it is on the other side of the Black Hills. Therefore, the data are likely not 

21 representative of conditions at the Ross Project area.

22

23 Stability-class information was collected using the Applicant’s meteorological station, which 

24 demonstrated that the class distributions were predominantly neutral approximately 62 percent 

25 of the time. Other calculated conditions were Stability Class D (17 percent) and Class E (Strata, 

26 2011a). The classification that results in the least vertical mixing (Class F) was approximately 

27 4.7 percent at the Ross Project area, while Classes A through C ranged from 3 percent to 6.7 

28 percent (Strata, 2011a).

29

30 Average annual mixing heights were not reported, although Wyoming has provided statewide 

31 mixing heights to be used in dispersion modeling (see Table 3.16) (Strata, 2011a).

32

Table 3.16

Statewide Mixing Heights for 

Dispersion Modeling

Stability Class

Mixing Height

(m [ft])

Class A 3,450 [11,319]

Class B 2,300 [7,546]

Class C 2,300 [7,546]

Class D 2,300 [7,546]

Class E 10,000 [32,808]

Class F 10,000 [32,808]

33 Source: Strata, 2011a.

34
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1 Stability classes E and F are given an arbitrarily high number by the WDEQ/Air Quality Division 

2 (AQD) to indicate an absence of a distinct boundary in the upper atmosphere.

3

4 3.7.2 Climatology

5

6 On a larger scale, climate change is a subject of national and international interest. The recent 

7 compilation of the current scientific understanding in this area by the U.S. Global Change 

8 Research Program (GCRP), a Federal advisory committee, was considered in preparation of 

9 this SEIS (GCRP, 2009). Average temperatures in the U.S. have risen more than 1.1 °C [2 °F] 

10 over the past 50 years and are projected to rise more in the future. During the period from 1993 

11 – 2008, the average temperature in the Great Plains increased by approximately 0.83 °C [1.5 

12 °F] from 1961 to 1979 baseline temperatures (GCRP, 2009). The projected change in 

13 temperature over the period from 2000 – 2020, which encompasses the period that the Ross 

14 Project would be licensed, ranges from a decrease of approximately 0.28 °C [0.5 °F] to an 

15 increase of approximately 1.1 °C [3.4 °F]. Although the GCRP did not incrementally forecast a 

16 change in precipitation by decade, it did project a change in spring precipitation from the 

17 baseline period (1961 – 1979) to the next century (2080 – 2099). For the region in Wyoming 

18 where the Ross Project is located, the GCRP forecast a 10 – 15 percent increase in spring 

19 precipitation (GCRP, 2009).

20

21 The EPA has determined that potential changes in climate caused by greenhouse gases (GHG) 

22 emissions endanger public health and welfare based on a body of scientific evidence assessed 

23 by the GCRP as well as the National Research Council (74 FR 66496). The Administrator of 

24 the EPA has issued an endangerment finding based on a technical support document compiled 

25 by these scientific organizations. This endangerment finding specifies that, while ambient 

26 concentrations of GHG emissions do not cause direct adverse health effects (such as 

27 respiratory issues or toxic effects), public health risks and impacts can result indirectly from 

28 changes in climate. Based on the EPA’s determination, the NRC recognizes that GHGs may 

29 have an effect on climate change. In Memorandum and Order CLI-09-21, the Commission 

30 provided guidance to NRC staff to consider carbon dioxide and other GHG emissions in its 

31 National Environmental Policy Act (NEPA) reviews (NRC, 2009a). GHG emissions, as 

32 projected for the Ross Project, are considered as an element of the air-quality impacts 

33 evaluation in this SEIS; GHG emissions are discussed in SEIS Section 5. 

34

35 3.7.3 Air Quality

36

37 As described in GEIS Section 3.4 

38 (NRC, 2009b), all of the NSDWUMR is 

39 classified as an attainment area for all 

40 the primary criteria pollutants under the 

41 National Ambient Air Quality Standards 

42 (NAAQS) (NRC, 2009b). (The EPA 

43 sets NAAQS for air pollutants 

44 considered harmful to public health and 

45 the environment [40 CFR Part 50]. 

46 Some states, such as Wyoming, also 

47 set their own Ambient Air Quality 

48 Standards, 

What is an air-quality attainment area?

The attainment status of an area refers to whether or not 

its air quality “attains” the National Ambient Air Quality 

Standards (NAAQS) for specific air pollutants. That is, an 

attainment area is a particular geographic area where the 

respective concentrations of primary (or “criteria”) air 

pollutants meet the health-based NAAQS for the 

corresponding primary air pollutants. If the area 

persistently exceeds the NAAQS for one or more primary 

air pollutants, it is classified as being in “non-attainment” 

for the particular air pollutant(s) that exceed(s) the 

respective NAAQS standard. The Powder River Basin is 

an attainment area for PM10.
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1 such as the Wyoming Ambient Air Quality Standards [WAAQS].) Primary NAAQS are 

2 established to directly protect public health, and secondary NAAQS are established to protect 

3 public welfare by safeguarding against environmental and property damage. As discussed in 

4 GEIS Section 3.4.6, the NAAQS defines acceptable ambient-air concentrations for six common 

5 nonradiological particulate and gaseous air pollutants (i.e., primary or criteria pollutants): 

6 nitrogen oxides (as NO2), ozone (O3), sulfur oxides (as SO2), carbon monoxide (CO), lead (Pb), 

7 and particulate matter (less than 10 and 2.5 μm in diameter [PM10 and PM2.5]). In particular, 

8 most of the Powder River Basin, where significant coal mining activities are ongoing, and which 

9 includes the Ross Project area, is currently designated an attainment area for all pollutants 

10 (Strata, 2011a). 

11

12 As noted above, states may develop standards that are more strict than or that supplement the 

13 NAAQS. The WDEQ/AQD has submitted a draft revision of its own WAAQS to the appropriate 

14 State boards. These revisions would result in Wyoming’s adding one-hour NO2 and SO2

15 standards and revoking the current 24-hour and 1-hour standards for SO2 of the existing 

16 WAAQS to be identical with NAAQS (see Table 3.17). The Wyoming-specific annual (arithmetic 

mean) PM10 standard of 50 μg/m3 17 , which is required for short-term modeling of surface coal 

18 mine emissions, will be retained. Some primary and secondary NAAQS are presented in Table 

19 3.17 (WDEQ/AQD, 2010).

20

21 The air quality in the vicinity of the Ross Project area is currently in compliance with the NAAQS 

22 for all primary air pollutants, including particulates (i.e., fugitive dusts) and combustion-engine 

23 gaseous emissions. 
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Table 3.17

National and Wyoming Ambient Air Quality Standards

Criteria 

Pollutant

National 

Primary

Standards

Wyoming 

Primary 

Standards

Averaging

Time

Secondary

Standards

Carbon Monoxide

9 ppm

(10,000 μg/m3)

9 ppm

(10,000 μg/m3) 8 Hours† N/A*

35 ppm

(40,000 μg/m3

)

35 ppm

(40,000 μg/m3) 1 Hour† N/A

Nitrogen Dioxide

0.053 ppm

(100 μg/m3)

0.05 ppm

(100 μg/m3)

Annual Arithmetic 

Mean Same as Primary

0.100 ppm

(187 μg/m3

)

0.100 ppm 

(187 μg/m3

) 1 Hour N/A

Particulate Matter

(10-μm Diameter)

(PM10)

150 μg/m3 150 μg/m3 24 Hours Same as Primary

N/A 50 μg/m3 Annual Arithmetic 

Mean N/A

Particulate Matter

(2.5-μm Diameter)

(PM2.5)

12.0 μg/m3 12.0 μg/m3 Annual Arithmetic 

Mean Same as Primary

35 μg/m3 35 μg/m3 24 Hoursa Same as Primary

Ozone 0.08 ppm

(157 μg/m3

)

0.08 ppm

(157 μg/m3) 8 Hoursb Same as Primary

Sulfur Oxides

N/A

23 ppm

(Will Revoke)

60 μg/m3

Annual Arithmetic 

Mean N/A

N/A

100 ppm 

(Will Revoke)

260 μg/m3 24 Hours† N/A

75 ppm

200 μg/m3

75 ppm

(Will Add)

200 μg/m3 1 Hour N/A

N/A 0.5 ppm

(1,300 μg/m3) 3 hours† 0.5 ppm

(1,300 μg/m3)

1 Source: Modified from EPA’s “National Ambient Air Quality Standards (NAAQS),” as of October 2011. 

2 Notes: 

3 † Not to be exceeded more than once per year.

4 * N/A = Not applicable.

a To attain this standard, the 3-year average of the 98th 5 percentile of 24-hour concentrations at each 

population-oriented monitor within an area must not exceed 35.0 μg/m3 6 (effective December 18, 2006).

b 7 To attain this standard, the 3-year average of the fourth highest daily maximum 8-hour average ozone 

8 concentrations measured at each monitor within an area over each year must not exceed 0.08 ppm.

9 Italics: Standard is in the rulemaking process in Wyoming. The intention is for WAAQS to reflect NAAQS, 

while retaining the State annual-average PM10 standard of 50 μg/m3 10 .
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1 3.7.3.1 Particulates 

2

3 “Particulates” refers to particles that are suspended in the air. Some particles are large enough 

4 to be seen (e.g., smoke and wind-blown dust), while others are too small to be visible. 

5 Agriculture, forestry, transportation, wind, and fire all contribute airborne particulates to the 

6 atmosphere. The NAAQS and WAAQS specify the allowable concentration of airborne 

particulates of 10 microns in diameter or smaller, or “PM10,” to 150 μg/m3 [9.4 x 10-9 lb/ft3 7 ] over 

8 24 hours (see Table 3.17). Wyoming has a supplemental annual (arithmetic mean) PM10

standard of 50 μg/m3 [3.1 x 10-9 lb/ft3 9 ] that is averaged over the year (WDEQ/AQD, 2010). The 

10 NAAQS also limits allowable concentrations of airborne particles that are 2.5 microns in 

11 diameter or smaller (PM2.5). Based on the pre-operational background data collected by the 

12 Applicant, three radionuclide particulates of interest (natural uranium, Ra-226 and Th-230) are 

13 found at concentrations at or below the minimum analytical detection limit and one radionuclide 

14 particulate (Pb-210) is found at concentrations just above the minimum analytical detection 

15 limits. The detected Pb-210 particulate levels are consistent with the background radon flux as 

16 Pb-210 is a progeny of the radon-222 decay.

17

18 The eastern portion of the Powder River Basin has an extensive network of PM10 monitoring 

19 stations that are operated by the mining industry because of the density of the coal mines in the 

20 region. There are five surface coal mines within approximately 48 km [30 mi] of the Ross 

21 Project area. PM10 compliance with the NAAQS and WAAQS 24-hour standards at these five 

22 mines (and, by inference, at the Ross Project area) has been consistently demonstrated by 

23 these stations (Strata, 2011a); However, there have been three small excursions over the 24-

24 hour PM10 at the mines that were determined to be due to high wind conditions. There are also 

25 monitoring stations operated by the WDEQ/AQD in the cities of Sheridan, Gillette, Arvada, and 

26 Wright, where particulates are generally measured as PM10. 

27

28 The WDEQ/AQD operates a PM2.5 particulate sampler at the Buckskin Mine, about 48 km [30 

29 mi] west of the Ross Project area. Ambient air-quality monitoring data from 2005 – 2009 from 

the Buckskin Mine show that the average PM2.5 ranged from 5.1 – 6.2 μg/m3 [3.2 – 3.9 x 10-10 30

lb/ft3

], about one-third the annual mean PM2.5 standard of 15 μg/m3 [9.4 x 10-10 lb/ft3 31 ]. No 

excursions above the 24-hour standard of 5 μg/m3 32 were recorded at the Mine. The data 

33 indicate that particulates from highway and non-road-construction vehicles comprise 

34 approximately 28 percent of the total PM10 and PM2.5 particulate emissions. 

35

36 As discussed in GEIS Section 3.4.6, prevention of significant deterioration (PSD) requirements

37 identify maximum allowable increases in concentrations for particulate matter for areas

38 designated as in attainment. Different increment levels are identified for different classification

39 areas, with Class I areas having the most stringent requirements. The nearest Class I areas to 

40 the Ross Project area is the Northern Cheyenne Indian Reservation (in Montana) and Wind 

41 Cave National Park (South Dakota); these areas are 130 km [80 mi] and 160 km [100 mi] from 

42 the Ross Project area, respectively. The other sensitive areas are the Class II Devils Tower and 

43 the Class II Cloud Peak Wilderness Area. These areas are approximately 16 km [10 mi] and 

44 130 km [80 mi], respectively, from the Ross Project area (Strata, 2011a).

45

46 3.7.3.2 Gaseous Emissions

47

48 Existing regional air pollutants are known to include gaseous emissions, such as NO2 and O3, 

49 which have been extensively monitored near the Ross Project area and in the Powder River 
DRAFT Affected Environment

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1 Basin since 1975 (Strata, 2011a). See Table 3.17, which presents both the respective NAAQS 

2 and WAAQS gaseous-emission standards. Radon is a gaseous air emission which is described 

3 further in SEIS Section 3.12.1 under Air. Based on the pre-operation background sampling, the 

4 radon concentrations in air through the Ross Project ranges from 0.5 to 2.0 pCi/L with a 

5 resultant exposure between 9.2 to 38.2 mrem. These values are consistent with expected 

6 background levels for radon in air overlying mineralized environments (Strata, 2011a).

7

8 Air-quality monitoring for gaseous emissions within the Powder River Basin includes measuring 

9 ozone (as O3) and nitrous oxides (as NO2) at two WDEQ/AQD stations, the closest of which is 

10 29 km [18 mi] from the Ross Project area. A Wyoming Air Resources Monitoring System 

11 (WARMS), which is operated by the BLM, monitors sulfur- and nitrogen-oxide concentrations 

12 near Buffalo, Sheridan, and Newcastle. Nitrogen oxides (as NO2) are also monitored by the 

13 WDEQ at the Thunder Mountain Basin National Grassland monitoring station, 29 km [18 mi] 

14 west of the Ross Project area as well as at private monitoring stations at the Belle Ayr and 

15 Antelope coal mines (see SEIS Section 5.2). All of these monitoring stations routinely indicate 

16 that the annual mean NO2 emissions are well below the NAAQS and WAAQS. 

17

18 Ozone is also monitored in the Powder River Basin which is considered an ozone attainment 

19 area. Although no violations of the ozone standard have occurred in the area, the levels 

20 reported by these nearby air-quality monitoring stations are sometimes close to the respective 

21 ozone standard.

22

23 PSD requirements also incorporate gaseous-emission standards (e.g., for NO2, SO2, and O3) for 

24 maximum allowable increases in concentrations for areas designated as in attainment. As 

25 discussed above, Class I areas have the most stringent requirements; Class I areas nearest to 

26 the Ross Project area are listed above in SEIS Section 3.7.3.2.

27

28 3.8 Noise

29

30 As described in GEIS Section 3.4.6, eastern Wyoming is predominantly rural and undeveloped, 

31 except for the heavily mined Powder River Basin. Rural areas tend to be quiet, and natural 

32 phenomena, such as wind, rain, 

33 insects, and livestock, tend to 

34 contribute the most to background 

35 noise. The unit of measure used to 

36 represent sound-pressure levels is 

37 the decibel (dB) (and on the A38 weighted scale, dBA or A-weighted 

39 decibel). dBA is a measure 

40 designed to simulate human 

41 hearing by placing less emphasis 

42 on lower frequency noises, 

43 because the human ear 

44 does not perceive sounds at low 

45 frequencies in the same manner as sounds at higher frequencies. In the undeveloped rural 

46 areas of Wyoming, the existing background ambient noise levels range from 22 decibels (dB) on 

47 calm days up to 38 dB, depending upon factors such as wind and traffic (NRC, 2009b). 

48

How Is sound measured?

The human ear responds to a wide range of sound pressures. 

The range of sounds people normally experience extends from 

low to high pressures by a factor of 1 million. Sound is 

commonly measured using decibels (dB). Another common 

sound measurement is the A-weighted sound level (dBA). The 

equivalent sound level is expressed as an A-weighted sound 

level over a specified period of time—usually 1 or 24 hours. 

The A-weighting measures different sound frequencies and the 

variation of the human ear’s response over the frequency range. 

Higher frequencies receive less A-weighting than lower ones. 
DRAFT Affected Environment

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1 It should be noted that noise levels 

2 lessen with increasing distance from 

3 the respective source. Noise from a 

4 line source, such as a highway, is 

5 reduced by approximately 3 dB per 

6 doubling of distance. For example, 

7 road noise at 15 m [49 ft] from a 

8 highway is reduced by 3 dB at 30 m 

9 [98 ft] and further reduced by an 

10 additional 3 dB at 60 m [197 ft]. For 

11 point sources, such as equipment, 

12 compressors, and pumps, the reduction factor with distance is greater, at approximately 6 dB 

13 per doubling of distance. 

14

15 The land uses in the Ross Project area (see Section 3.2) include livestock grazing, oil 

16 production, crop production, ordinary transportation, recreation, and wildlife habitat. Existing 

17 ambient noise levels at the Ross Project area were measured by the Applicant to establish pre18 licensing baseline conditions at the residences located on New Haven Road and 11 residences 

19 in a 3-km [2-mi] vicinity of the Ross Project. Future site-specific noise levels associated with 

20 uranium-recovery activities would be measured against these baseline conditions to identify 

21 relative increases in noise levels. 

22

23 The baseline noise study specifically studied the two nearest residences to the Ross Project. 

24 The first nearest residence is 210 m [690 ft] from the Ross Project’s boundary and 

25 approximately 762 m [2,500 ft] from the location of the CPP in the Proposed Action. The 

26 second residence is 255 m [835 ft] from the boundary and 1,707 m [5,600 ft] from the proposed 

27 location of the CPP. Because these residences are so close to the Ross Project area, they 

28 bound the upper range of noise for all four of the residences next to the Ross Project area, 

29 where all of the residences are located within 0.48 km [0.3 mi] of the Ross Project’s boundary 

30 (Strata, 2011a). The noise levels at these two residences averaged 35.4 dBA and 37.4 dBA, 

31 depending upon simultaneous factors such as wind speed, traffic volume, vehicular speed, and 

32 the type of load being transported (Strata, 2011a). 

33

34 Truck traffic, in particular bentonite hauling from the Oshoto bentonite mine 5 km [3 mi] north of 

35 the Ross Project area and, less frequently, livestock hauling, are the main contributors to 

36 existing traffic noise on D and New Haven Roads. According to the U.S. Department of 

37 Transportation (USDOT), typical noise levels at road speeds ranging from 80 – 113 km/hr [50 –

38 70 mi/hr] are 62 – 68 dBA (passenger automobiles), 74 – 79 dBA (medium trucks), and 80 – 82 

39 dBA (heavy trucks) (USDOT, 1995). Posted speed limits for D Road, which passes adjacent to 

40 the Ross Project area, are 88 km/hr [55 mi/hr] for automobiles and 72 km/hr [45 mi/hr ] for 

41 trucks. Peak noise levels attributed to truck traffic have been measured at 80 – 90 dBA (Strata, 

42 2011a). A passing truck hauling bentonite registered 73.4 dBA at the residence on New Haven 

43 Road.

44

45 In a separate noise study, the Applicant collected baseline measurements at the Applicant’s 

46 Field Office for an entire week; the data yielded an average day-night noise level (ldn) of 41.6 

47 dBA overall, with no variance between weekday and weekend measurements (Strata, 2011a). 

48 The ldn is the A-weighted equivalent noise level for a 24-hour period that includes a noise level 

What is noise?

Sound waves are characterized by frequency and 

measured in hertz (Hz). Noises that are perceptible to 

human hearing range from 31 to 20,000 Hz. Audible 

sounds (those that can be heard) range from about 60 dB 

at a frequency of 31 Hz to less than about 1 dB between 

900 and 8,000 Hz. dBAs assume a human receptor to a 

particular noise-producing activity.
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1 at nighttime that is 10 dBA lower than the daytime noise level. Nighttime hours are considered 

2 to be from 10 p.m. to 7 a.m. (EPA, 1978).

3

4 The Wyoming Department of Transportation (WYDOT) has defined Noise Abatement Criteria 

5 (NAC) that take into account land use, because different land-use areas are sensitive to noise in 

6 different ways (NACs are used for impact determinations only). The WYDOT procedures 

7 consider a person to be affected by traffic noise from highways when existing or future sound 

8 levels approach or exceed the NAC, or when expected future sound levels exceed existing 

9 sound levels by 15 dBA. In addition, the sound characteristics of noise can affect the 

10 acceptability of noise levels to receptors and the acceptability of noise levels is increased when 

11 the noise is familiar and routine (WYDOT, 2011). There are no NACs for undeveloped land. 

12 The exterior of residential structures would be considered affected by highway traffic above 67 

13 dBA Leq(h) (i.e., equivalent continuous noise level).

14

15 Ambient noise levels in larger communities would be expected to be similar to other urban areas 

16 (i.e., approximately 50 – 78 dBA). However, the nearest cities to the Ross Project are all quite 

17 distant from the Ross Project area and are, thus, not expected to be affected by the noise levels 

18 at the Ross Project (nor, conversely, affect the noise levels from the Ross Project). For 

19 example, Casper, Wyoming, which has a population of 55,000 and is 225 km [140 mi] away 

20 from the Ross Project area (USCB, 2010), and smaller communities, such as Hulett and 

21 Moorcroft, which are located 22 km [14 miles] and 35 km [22 miles] away from the Ross Project 

22 area, respectively, are too distant to contribute to the noise environment at the Ross Project 

23 area.

24

25 3.9 Historical, Cultural, and Paleontological Resources

26

27 Both NEPA and the National Historic Preservation Act of 1966 (NHPA), as amended, require 

28 Federal agencies to consider the effects of their undertakings on historical and cultural 

29 properties. The historic preservation review process is outlined at regulations promulgated by 

30 the Advisory Council on Historic Preservation in 36 CFR Part 800. Historical properties are 

31 resources eligible for listing in the National Register of Historic Places (NRHP) and may include 

32 sites, buildings, structures, districts, or objects. Amendments to Section 101 of the NHPA in 

33 1992 explicitly allowed properties of traditional religious and cultural importance to be eligible for 

34 inclusion on the NRHP (and the Wyoming Register of Historic Places). Eligible properties 

35 generally must be at least 50 years old and possess criteria of eligibility as defined in 36 CFR 

36 Part 60.4; these criteria include: 1) association with significant events in the past, 2) association 

37 with the lives of persons significant in the past, 3) embodiments of distinctive characteristics of 

38 type, period, or construction, or 4) yield or be likely to yield important information. Historical 

39 properties must also possess integrity, defined as the ability of a property to convey its 

40 significance (NPS, 1997a).

41

42 NEPA established the responsibility of the Federal government to employ all practicable means 

43 to preserve important historical, cultural, and natural aspects of national heritage. Implementing 

44 regulations for Section 106 provide guidance on how NEPA and Section 106 processes can be 

45 coordinated (at Section 800.8[a]) and set forth the manner in which the NEPA process and its 

46 documentation can be used to comply with Section 106 (Section 800.9[c]). The NHPA 

47 regulations also address the Federal government’s responsibility to identify historical and 

48 cultural properties and assess the effects of a given Federal undertaking on those properties 

49 (Sections 800.4 through 800.5).
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1 As a Federal undertaking, the issuance of an NRC source and byproduct material license for the 

2 Ross Project has the potential to affect historic properties located on, in, beneath, or near the 

3 Ross Project area. The NRC is required, in accordance with the NHPA, to make a reasonable 

4 effort to identify historic properties in the area of potential effect (APE) for the Project. The APE 

5 is defined by the Ross Project site boundary and its immediate environs, which may be 

6 impacted by the Ross Project construction, operation, aquifer restoration, and decommissioning 

7 activities. If historic properties are known to be present, the NRC is required to assess the 

8 effects of its issuing a license for uranium-recovery operations on identified properties and to 

9 resolve any adverse impacts to those properties.

10

11 Several additional statutes and EOs apply to Federal land managed by the BLM, most notably 

12 the Native American Graves Protection and Repatriation Act (NAGPRA) and the Archaeological 

13 Resources Protection Act (ARPA). NAGPRA is applicable to burials found on BLM-managed 

14 lands, and in that context provides for the protection of Native American remains, funerary 

15 objects, sacred objects, or objects of cultural patrimony, and their repatriation to affiliated Native 

16 American Tribes following a consultation process between Tribes and the land managing 

17 federal agency. ARPA regulates the permitting of archaeological investigations on public land, 

18 including those managed by BLM. The State of Wyoming also has a statute pertaining to 

19 archaeological sites and human remains, entitled Archaeological Sites (Wyoming Statute Ann. 

20 §36-1-114, et seq.). The Wyoming State Historic Preservation Office (SHPO) administers and 

21 is responsible for oversight and compliance review for Section 106 of the NHPA and NAGPRA 

22 as well as compliance with other Federal and State historic-preservation statutes and 

23 regulations. The Wyoming SHPO and the Wyoming State Office of the BLM have entered into a 

24 programmatic agreement that describes the manner in which the two entities would interact and 

25 cooperate under the BLM’s National Programmatic Agreement.

26

27 3.9.1 Cultural Context of Ross Project Area

28

29 The following information is provided as an aid to the reader to understand the Ross Project 

30 area in terms of potential prehistoric and historic events that would reasonably be expected to 

31 have occurred and that would have left behind artifacts (archaeological resources) of interest to 

32 present-day archeologists, paleontologists, and present-day Native American Tribes of this 

33 area. 

34

35 The Ross Project area is within a portion of Wyoming inhabited by aboriginal hunting and 

36 gathering people for more than 13,000 years. Throughout the prehistoric past, this area was 

37 used by highly mobile hunters and gatherers who exploited a wide variety of resources. The 

38 immense expanse of grassland in the Plains region was home to vast herds of bison, also 

39 known as buffalo. Exploitation of this resource by indigenous groups structured the Northwest 

40 Plains culture area. Fur traders, explorers, and military men were the first Euro-Americans to 

41 enter the region and encounter the mounted Indians of the region. These bison-dependent 

42 people and their way of life were eventually displaced by permanent farming and ranching 

43 settlement.

44 3.9.1.1 Prehistoric Era

45

46 Past research activities within the Northwestern Plains culture area have defined a sequence of 

47 cultural periods that provide a general context for identification and interpretation of 

48 archaeological resources within the proposed Ross Project area. This chronology for the 
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1 Northwestern Plains was developed from the work of Frison (1991; 2001) with age ranges 

2 provided in years Before Present (B.P.): 

3

4 ■ Paleoindian period (13,000 – 7,000 years B.P.)

5 ■ Early Archaic period (7,000 – 5,000 years B.P.)

6 ■ Middle Archaic period (5,000 – 4,500 to 3,000 years B.P.)

7 ■ Late Archaic period (3,000 – 1,850 years B.P.)

8 ■ Late Prehistoric period (1,850 – 400 years B.P.)

9 ■ Protohistoric period (400 – 250 years B.P.)

10 ■ Historic period (250 – 120 years B.P.)

11

12 The most-recent two cultural periods, about which more is known, are more thoroughly 

13 discussed in a separate section below.

14

15 The Paleoindian period includes various complexes (Frison, 1991; Frison, 2001). Each of these 

16 complexes is correlated with a distinctive projectile point style derived from generally large, 

17 lanceolate and/or stemmed point morphology. The Paleoindian period is traditionally thought to 

18 be synonymous with the "big game hunters" who exploited megafauna such as bison and 

19 mammoth (Plains Paleoindian groups), although evidence of the use of vegetal resources has 

20 been noted at a few Paleoindian sites (foothill-mountain groups).

21

22 The Early Archaic period projectile point styles reflect the change from large lanceolate types 

23 that characterized the earlier Paleoindian complexes to large side- or corner-notched types. 

24 Subsistence patterns reflect exploitation of a broad spectrum of resources, with a much25 diminished use of large mammals.

26

27 The onset of the Middle Archaic period has been defined on the basis of the appearance of the 

28 McKean Complex as the predominant complex on the Northwestern Plains around 4,900 years 

29 B.P. (Frison, 1991; Frison, 2001). McKean Complex projectile points are stemmed variants of 

30 the lanceolate point. These projectile point types continued until 3,100 years B.P. when they 

31 were replaced by a variety of large corner-notched points (e.g., Pelican Lake points) (Martin, 

32 1999, as cited in Strata, 2011a). Sites dating to this period exhibit a new emphasis on plant 

33 procurement and processing.

34

35 The Late Archaic period is generally defined by the appearance of corner-notched dart points. 

36 These projectile points dominate most assemblages until the introduction of the bow and arrow 

37 around 1,500 years B.P. (Frison, 1991). This period witnessed a continual expansion of 

38 occupations into the interior grassland and basins, as well as the foothills and mountains.

39 The Late Prehistoric period is marked by a transition in projectile point technology around 1,500 

40 years B.P. The large corner-notched dart points characteristic of the Late Archaic period are 

41 replaced by smaller corner- and side-notched points for use with the bow and arrow. 

42 Approximately 1,000 years B.P., the entire Northwestern Plains appears to have suffered an 

43 abrupt collapse or shift in population (Frison, 1991). This population shift appears to reflect a 
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1 narrower subsistence base focused mainly on communal procurement of pronghorn antelope 

2 and bison.

3

4 3.9.1.2 Protohistoric/Historic Periods

5

6 The Protohistoric period witnessed the beginning of European influence on prehistoric cultures 

7 of the Northwestern Plains. Additions to the material culture include, most notably, the horse 

8 and European trade goods, including glass beads, metal, and firearms. Projectile points of this 

9 period include side-notched, tri-notched, and un-notched points, with the addition of metal 

10 points. Introduction of the horse on the southern Plains in the 1600s spread northward to other 

11 Tribes, and mounted buffalo hunters became the classic Plains culture known in the period of 

12 Euro-American contact. New diseases also spread across the continent with the first arrival of 

13 Europeans, affecting Native peoples even before the physical appearance of the newcomers.

14

15 The Plains Tribes shared a basic commonality of style in their material culture, with regional and 

16 Tribal variation. This material culture was strongly characterized by its dependence on bison. 

17 Bison played a part in all aspects of physical life by providing food, clothing, shelter, tools, and 

18 fuel (dung), as well as embodying a spiritual force (DeMallie, 2001). The need to follow the 

19 seasonal movements of bison herds resulted in seasonal variation in residential patterns. 

20 Summer encampments of large groups gathered to hunt, using cooperative hunting techniques 

21 such as driving a herd over a cliff (buffalo jump sites) or into a corral at the bottom of a slope or 

22 a cut bank. 

23

24 Extended family and village groups moved along with the herds, hauling their belongings and 

25 portable dwellings to new encampments. Originally, long, low, multiple-family tents, the classic 

26 Plains teepee built on a foundation of supporting poles, developed following the adoption of the 

27 horse (DeMallie, 2001). Extended families were organized in nomadic bands or semi-sedentary 

28 villages, each independent but sharing the same language and culture, with the size of their 

29 aggregations determined by ecological factors. Communal hunting needed for the bison hunts 

30 gave way to smaller, scattered social groups that were optimal at other times. The need for 

31 horse pasturage also limited the size and duration of residential groups. Smaller Tribes stayed 

32 together more of the year, but large Tribes might only congregate for summer hunts. The 

33 largest Tribes, such as the Blackfoot and Crow, might rarely gather in a single place and tended 

34 toward more lasting divisions that can be viewed as separate Tribes with their own territories 

35 and linguistic distinctions (DeMallie, 2001).

36

37 Plains groups shared a fundamental belief in the power inherent in all living beings. This power 

38 was accessible to individuals in dreams and visions but was particularly useful to medicine men 

39 and priests, whose more heightened understanding and experience of power gave them a 

40 special role in the ritual life of Plains communities. Sacred power was acquired by individuals 

41 through vision seeking during a retreat and accompanied by fasting and prayer while awaiting 

42 the appearance of spiritual beings in a special form, sometimes an animal that embodied a 

43 teaching and protective spirit (DeMallie, 2001).

44 During the historic period, the Plains Tribes came under duress from the effects of a rapidly 

45 changing world. As soldiers, settlers, bison hunters, and other Tribal nations pushed westward, 

46 epidemic diseases ravaged the native populations, and the dislocation of conflict increased, 

47 leading to changing demographic patterns and a breakdown of traditional systems of food 

48 gathering and inter-group exchange patterns. As missionaries came onto the Plains they 
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1 professed belief systems that conflicted with, and sometimes even forbade, native traditional 

2 rites related to a life view that often mingled the spirit and physical worlds. The influx of trading 

3 post goods, the shift in hunting patterns, and the loss of access to the seasonal migrations of 

4 prey produced a distorting effect that challenged native life. Cultural transformation was rapid, 

5 and was characterized by a long period of hostilities with the white settlers and disagreements 

6 among various Tribal entities regarding the course of action in the face of encroachment. 

7 Eventual resolution of conflict came through military means and treaties that established the 

8 present-day reservation system.

9

10 The only Tribal reservation in Wyoming is the Wind River Indian Reservation, located 

11 approximately 273.6 km [170 mi] southwest of the Ross Project. The Crow and Northern 

12 Cheyenne Indian Reservations in Montana (approximately 160 and 146 km [100 and 91 mi] 

13 northwest, respectively) and the Pine Ridge Indian Reservation in South Dakota (approximately 

14 185 km [115 mi] southeast) are the other Tribal reservation communities nearest the proposed 

15 Ross Project site. A review of the literature indicates that Devils Tower, which is called Mato 

16 Tipila by some Native Americans which means “Bear Lodge” (other names for Devils Tower 

17 include: Bear’s Tipi, Home of the Bear, Tree Rock and Great Gray Horn) (NPS, 2012), (located 

18 approximately 18 km [10 mi] from the Ross Project) is a sacred area for several Plains Tribes 

19 (Hanson and Chirinos, 1991, as cited in Strata, 2011a). According to the U.S. National Park 

20 Service (NPS), over 20 Tribes have potential cultural affiliation with Devils Tower. Six Tribes 

21 (Arapaho, Crow, Lakota, Cheyenne, Kiowa, and Shoshone) have historical and geographical 

22 ties to the Devils Tower area (NPS, 1997b). Many Native American Tribes of the northern 

23 Plains refer to Devils Tower in their legends and consider it a sacred site. 

24

25 3.9.1.3 Historic Era 

26

27 The historical context of the Ross Project area includes several themes common to all of 

28 northeastern Wyoming. The earliest cumulative historic impact was associated with intermittent 

29 exploration, fur trapping, gold seeking, and military expedition, circa 1810s – 1870s. This era 

30 was followed by large-scale stock raising (1870s – 1900s). The dry-land farming/homesteading 

31 movement was the most substantial historic expansion, occurring from the 1910s – 1930s. The 

32 Great Depression resulted in the government assistance programs of the mid- to late-1930s, 

33 which affected the settlement patterns of this region. Post-war ranching (1945 to present) is the 

34 latest historic theme. Crook County, where the Ross Project is situated, was formed in 1875 

35 and named for Brigadier General George Crook, a commander during the Indian Wars.

36

37 Although Euro-Americans began to pass through Wyoming in the early 1800s, these visits were 

38 limited to government expeditions of discovery and various British and American fur trapping 

39 brigades. Beginning in the 1840s, emigrants of the "great western migration" passed along the 

40 Oregon-California Trail along the Platte River and through South Pass heading for lands in 

41 Oregon, California, and the Salt Lake Valley, but few if any stayed on in the region. As the 

42 lands in the west became more populated and the cattle industry made its way into Wyoming in 

43 the 1860s, the region began to attract its own settlers.

44

45 The Texas Trail, which operated from 1876 – 1897, was used to move cattle as far north as 

46 Canada. Most of the early cattle herds passed through Wyoming and were used to establish 

47 Montana's ranching industry. As cattlemen recognized the value of Wyoming's grassland, 

48 several large cattle ranches were established and flourished until the devastating blizzards in 

49 the winter of 1886-1887. The close of the cattle baron era provided an opening for Wyoming's 
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1 sheep industry. Several large ranches, including the 4J and G-M, were established in the 

2 Gillette area south of the proposed Ross Project; however, the industry experienced steady 

3 declines in the 1900s (Massey, 1992; Rosenberg, 1991, as cited in Ferguson, 2010). The dry4 land farming movement of the late 19th and early 20th centuries had a profound effect on the 

5 settlement of northeastern Wyoming during the years around World War I. The most intensive 

6 period of homesteading activity in northeastern Wyoming occurred in the late 1910s and early 

7 1920s. Promotional efforts by the State and the railroads, the prosperous war years for 

8 agriculture in 1917 and 1918, and the Stock Raising Act of 1916 with its increased acreage (but 

9 lack of mineral rights) all contributed to this boom period. It soon became evident, however, that 

10 dry-land farming alone would not provide a living and farmers began to increase their livestock 

11 holdings (Ferguson, 2010).

12

13 A severe drought in 1919 followed by a severe winter, along with a fall in market prices in 1920, 

14 forced out many small holders. During the 1920s the size of homesteads in Wyoming nearly 

15 doubled while the number of homesteads decreased, indicating the shift to livestock raising 

16 (LeCompte and Anderson 1982, as cited in Strata, 2011a). A period of drought began in 1932, 

17 leading to Federal drought relief programs. In April of 1932, the Northeast Wyoming Land 

18 Utilization Project began repurchasing the sub-marginal homestead lands and making the 

19 additional acres of government land available for lease. Two million acres within five counties, 

20 including about 226,624 ha [560,000 ac] of Federally-owned lands, were included in the 

21 Thunder Basin Project (LA-WY -1) to alter land use and to relocate settlers onto viable farmland 

22 (Resettlement Administration, 1936, as cited in Ferguson, 2010).

23

24 During the development program to rehabilitate the range, impounding dams were erected, 

25 wells were repaired, springs developed, and homestead fences removed while division fences 

26 were constructed for the new community pastures. The government paid former farmers to 

27 remove homesteads and their efforts were so successful that almost no trace remains. The 

28 remaining subsidized ranches were significantly larger and provided a stabilizing effect on the 

29 local economies. The Thunder Basin Grazing Association, the Spring Creek Association, and 

30 the lnyan Kara Grazing Association were formed to provide responsible management of the 

31 common rangeland.

32

33 Uranium was first discovered in Wyoming in 1918 near Lusk. Nuclear Dynamics and Bethlehem 

34 Steel Corporation formed the Nubeth Joint Venture (Nubeth) to develop new uranium recovery 

35 districts in the western U.S. with specific attention focused on northeastern Wyoming's Powder 

36 River Basin (Strata, 2011a). The initial discovery of uranium near Oshoto was made by Albert 

37 Stoick during an over-flight of the area. This was followed by macroscopic sampling efforts and 

38 then regional exploration work by the Nubeth Joint Venture (Nubeth) (Buswell, 1982, as cited in 

39 Strata, 2011a). Nubeth received a Wyoming Department of Environmental Quality/Land Quality 

40 Division (WDEQ/LQD) License to Explore (No. 19) in August 1976 and an NRC license in April 

41 1978 (No. SUA-1331). The Nubeth research and development facility was constructed and 

42 operated from August 1978 through April 1979. No precipitation of a uranium product took 

43 place, however, and all recovered uranium was stored as a uranyl carbonate solution. All final 

44 approvals for Nubeth's decommissioning were granted by the NRC and WDEQ by 1986 (Strata, 

45 2011a).
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1 3.9.2 Historical Resources

2

3 Buildings and Structures

4

5 No buildings or structures eligible for the NRHP or Wyoming State Register were identified 

6 within the Ross Project area (Ferguson, 2010). An earthen structure in the Ross Project area, 

7 the Oshoto Dam, did not meet the criteria for eligibility for listing in the NRHP (48 CFR Part

8 2157). The original dam has been rebuilt numerous times because of flood damage, most 

9 recently in 2005, and is considered to be essentially a reconstruction rather than the original 

10 dam.

11

12 Archaeological Sites

13

14 A Class III Cultural Resource Inventory (Class III Inventory) was conducted in support of the 

15 Ross Project in April 2010 and July 2010 (Ferguson, 2010). The Inventory included a 

16 pedestrian survey in transects of 30-m [102-ft] intervals throughout the Ross Project area. 

17 Subsurface exposures such as cut banks, anthills, rodent burrows, roads ruts, and cow tracks 

18 were examined. Shovel probes were placed at the discretion of the surveyors, primarily in 

19 locations where artifacts or features were located or where soil had accumulated. The Inventory 

20 focused on landforms where intact sites might be expected, such as intact, stable terraces and 

21 their margins as well as areas of exposure (Ferguson, 2010). In November 2011, a geophysical 

22 investigation consisting of a magnetometer survey was conducted at several sites within the 

23 Ross Project Area and additional shovel tests were conducted in May 2012 and June 2012.

24

25 In preparation for the Class Ill Inventory, a Class 1 Inventory (i.e., a records search) was 

26 conducted for the Ross Project area in 2010; this search included the records of the Wyoming 

27 Cultural Records Office (WYCRO), the WYCRO online data base, and the BLM’s Newcastle 

28 Field Office (Ferguson, 2010).

29

30 The records search showed that, prior to the 2010 Class III Inventory, no substantial block 

31 inventory (i.e., survey) had been conducted in the Project area. Small-scale investigations, 

32 including two associated with power lines and buried telephone cables as well as a drilling-pad 

33 and access-road survey, have been conducted in the Ross Project area. Only one survey, an 

34 inventory for a linear buried telephone cable in Section 13, identified one prehistoric campsite, 

35 48CK1603. Avoidance of this campsite was recommended as a result. The campsite lies on 

36 both State of Wyoming and private land, and it was described as “bisected” by D Road

37 (Ferguson, 2010). 

38

39 During the Applicant’s Class III Inventory for the Ross Project, 24 new sites and 21 isolated 

40 finds were recorded. Twenty-three of the recorded sites are prehistoric camps, and one is a 

41 historic-period homestead. The 24 sites along with the previously identified 48CK1603 are 

42 listed in Table 3.18. Paleontological materials, believed to be out of context, were found at two 

43 of the sites. These two sites produced projectile points that represent Middle Archaic and Late 

44 Archaic periods; other fragments found indicate Late Prehistoric-period occupation. Twenty-one 

45 isolates were also recorded during the Inventory. All but two of these are prehistoric artifacts; 

46 the two historic isolates are trash scatters. In addition to the sites identified during the Class Ill 

47 Inventory, the potential exists for deeply buried sites to be found within the Ross Project area 

48 because of its propitious location near the headwaters of the Little Missouri River.
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1 Fifteen sites identified for the Ross Project have been recommended by the Applicant as eligible 

2 for the NRHP (Ferguson, 2010). These are: Nos. 48CK1603, 48CK2073, 48CK2075, 

3 48CK2076, 48CK2078, 48CK2079, 48CK2080, 48CK2081, 48CK2082, 48CK2083, 48CK2085, 

4 48CK2089, 48CK2090, 48CK2091, and 48CK2092. All of these sites are considered eligible 

5 under Criterion D of the NRHP, because they are likely to yield information important to our 

6 knowledge of prehistory. Collectively or individually, the sites have the potential to yield 

7 important information about the occupations at the headwaters of the Little Missouri River and 

8 possibly to add to the understanding of the prehistoric cultural relationships between the Little 

9 Missouri River region and the Powder River Basin. Two of the sites, Nos. 48CK2083 and 

10 48CK2091, also provide temporal information (Ferguson, 2010).

11

12 In general, the Class III Inventory considered that sites located on intact terrace settings, where 

13 site preservation was sufficient for research purposes, were recommended as eligible. The 

14 remaining nine sites, where landforms lacked soil development and surfaces were eroded or 

15 deflated, were not considered likely to retain additional research potential. The NRC staff is in 

16 the process of consulting with the Applicant, interested Tribes, and Wyoming SHPO to evaluate 

17 the archaeological sites identified during the Applicant’s Class III Inventory.

18

19 3.9.3 Cultural Resources

20

21 Implementing regulations for NHPA, specifically 36 CFR Part 800.4l(a)(1), require the NRC to 

22 determine and document the respective APE in consultation with the Wyoming SHPO and the 

23 Tribal Historic Preservation Offices (THPOs) (36 CFR Part 800). The definition of an APE is 

24 defined in 36 CFR Part 800.16(d) as the geographic area or areas within which an undertaking 

25 may directly or indirectly cause alterations in the character or use of historic properties, if any 

26 such properties exist (36 CFR Part 800). The APE is influenced by the scale and nature of an 

27 undertaking, and it may be different for different types of effects caused by the undertaking.

28

29 The APE for the Ross Project area would include all lands where construction, operation, 

30 aquifer restoration, and decommissioning activities are proposed. This would include 

31 associated staging areas and new access roads in addition to the actual footprint of ground 

32 disturbance. In addition, the APE for the Ross Project would need to take into account 

33 additional areas where potential effects to traditional cultural properties (TCPs) are identified.

34

35 3.9.3.1 Culturally Significant Locations

36

37 No Native American heritage, special interest, or sacred sites have been formally identified or 

38 recorded to date that are directly associated with the Ross Project area. The geographic 

39 position of the Project area between mountains considered sacred by various Native American 

40 cultures (the Big Horn Mountains to the west, the Black Hills and Devils Tower to the east), 

41 however, creates the possibility that existing, specific locations could have special religious or 

42 sacred significance to Native American groups. 

43 3.9.3.2 Tribal Consultation

44

45 According to Executive Order (EO) No. 13175, Consultation and Coordination with Indian Tribal 

46 Governments, the NRC is encouraged to “promote government-to-government consultation and 

47 coordination with Federally-recognized Tribes that have a known or potential interest in existing 

48 licensed uranium-recovery facilities or applications for new facilities” (NRC, 2009b). Although 
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1 the NRC, as an independent regulatory agency, is explicitly exempt from the Order, NRC 

2 remains committed to its spirit. The agency has demonstrated a commitment to achieving the 

3 Order’s objectives by implementing a case-by-case approach to interactions with Native 

4 American Tribes. NRC’s case-by-case approach allows both NRC and the Tribes to initiate 

5 outreach and communication with one another. 

6

7 As part of its obligations under Section 106 of the NHPA and the regulations at 36 CFR 

8 800.2(c)(2)(B)(ii)(A), the NRC must provide Native American Tribes “a reasonable opportunity to 

9 identify its concerns about historic properties, advise on the identification and evaluation of 

10 historic properties and evaluation of historic properties, including those of religious and cultural 

11 importance, articulate its views on the undertaking’s effects on such properties, and participate 

12 in the resolution of adverse effects.” Tribes that have been identified as potentially having 

13 concerns about actions in the Powder River Basin include the Assiniboine and Lakota 

14 (Montana), Blackfoot, Blood (Canada), Crow, Cheyenne River Lakota, Crow Creek Lakota, 

15 Devil's Lake Lakota, Eastern Shoshone, Flandreau Santee Dakota, Kootenai and Salish, Lower 

16 Brule Lakota, Northern Arapaho, Northern Cheyenne, Oglala Lakota, Pigeon (Canada), 

17 Rosebud Lakota, Sisseton-Wahpeton Dakota, Southern Arapaho, Southern Cheyenne, 

18 Standing Rock Lakota, Three Affiliated Tribes, Turtle Mountain Chippewa, and Yankton Dakota 

19 (NPS, 2010). On February 9, 2011, the NRC staff formally invited 24 Tribes (see SEIS Section 

20 1.7.3.2) to participate in the Section 106 consultation process for the proposed Ross Project.

21 The NRC staff invited the Tribes to participate as consulting parties in the NHPA Section 106 

22 process and sought their assistance in identifying Tribal historic sites and cultural resources that 

23 may be affected by the proposed action.

24

25 SEIS Section 1.7.3.2 describes in detail the consultation activities undertaken by NRC with 

26 Tribal governments. At this time, the NRC staff is coordinating with interested Tribes to conduct 

27 a survey of the Ross Project area to identify sites of religious and cultural significance to Tribes. 

28 Correspondence and other documents related to the NRC’s Section 106 Tribal consultation 

29 efforts are listed in Appendix A.
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Table 3.18

Historic and Cultural Properties Identified within the Ross Project Area

Smithsonian Number Preliminary NRHP 

Eligibility 

Recommendationa

Cultural 

Affiliation/Site Type

48CK1603 Eligible Prehistoric campsite

48CK2070 Not eligible Prehistoric artifact and 

possible stone ring

48CK2071 Not eligible Prehistoric campsite

48CK2072 Not eligible Late prehistoric 

campsite

48CK2073 Eligible Prehistoric campsite

48CK2074 Not eligible Prehistoric campsite

48CK2075 Eligible Unknown prehistoric 

camp site

48CK2076 Eligible Prehistoric stone 

feature; Historic cans

48CK2077 Not eligible Prehistoric campsite

48CK2078 Eligible Unknown prehistoric 

camp site; historic 

debris

48CK2079 Eligible Unknown prehistoric 

camp site

48CK2080 Eligible Unknown prehistoric 

camp site

48CK2081 Eligible Unknown prehistoric 

camp site

48CK2082 Eligible Unknown prehistoric 

camp site

48CK2083 Eligible Late Archaic 

Prehistoric campsite

48CK2084 Not eligible Prehistoric campsite

48CK2085 Eligible Unknown prehistoric 

camp site

48CK2086 Not eligible Prehistoric campsite

48CK2087 Not eligible Unknown cairn

48CK2088 Not eligible Historic homestead 

(Maros Homestead)

48CK2089 Eligible Prehistoric campsite
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Table 3.18

Historic and Cultural Properties Identified within the Ross Project Area 

(Continued)

Smithsonian Number Preliminary NRHP 

Eligibility 

Recommendationa

Cultural 

Affiliation/Site Type

48CK2090 Eligible Unknown prehistoric 

camp

48CK2091 Eligible Middle Archaic camp

48CK2092 Eligible Unknown prehistoric 

camp

48CK2093 Not eligible Prehistoric lithic 

scatter

a 1 The eligibility recommendations reflected in this table are those provided by the Applicant’s consultant as 

2 reflected in the Class III survey report. However, the NRC staff’s review of the Applicant’s eligibility 

3 recommendations for the identified sites is ongoing. Therefore, for the purposes of this NEPA document, 

4 those sites that the applicant has recommended as not eligible will be treated as eligible.

5

6 3.10 Visual and Scenic Resources

7

8 The Ross Project area is located in a 

9 landscape of gently rolling topography 

10 and large, open expanses of upland 

11 grassland, pasture- and haylands, 

12 sagebrush shrubland, and intermittent 

13 riparian drainages. Intermittent 

14 streams are fed by ephemeral 

15 drainages that seasonally drain the 

16 adjacent uplands. A mountainous 

17 landscape east of the Ross Project can 

18 be seen; this landscape includes Devils 

19 Tower and the Missouri Buttes. 

20

21 To quantify visual and scenic resources 

22 on the land it administers, the BLM has 

23 established an evaluation methodology 

24 that defines the visual and scenic 

25 quality of land through a Visual 

26 Resource Inventory (VRI). The VRI 

27 process provides a means for 

28 determining visual values. The VRI 

29 consists of a scenic-quality evaluation, 

30 sensitivity-level analysis, and a 

31 delineation of distance zones. Based

32 on these three factors, BLM33 administered lands are placed into one 

34 of four VRI classes. 

What are the objectives for the visual resource 

classes?

Class I: To preserve the existing character of the 

landscape. This class provides for natural ecological 

changes; however, it does not preclude very limited 

management activity. The level of change to the 

characteristic landscape should be very low and must not 

attract attention.

Class II: To retain the existing character of the 

landscape. The level of change to the characteristic 

landscape should be low. Management activities may be 

seen, but should not attract the attention of the casual 

observer. Any changes must repeat the basic elements 

of form, line, color, and texture found in the predominant 

natural features of the characteristic landscape.

Class III: To retain partially the existing character of the 

landscape. The level of change to the characteristic 

landscape should be moderate. Management activities 

may attract attention but should not dominate the view of 

the casual observer. Changes should repeat the basic 

elements found in the predominant natural features of the 

characteristic landscape.

Class IV: To provide for management activities that 

require major modifications of the existing character of the 

landscape. The level of change to the characteristic 

landscape can be high. These management activities 

may dominate the view and be the major focus of viewer 

attention. However, every attempt should be made to 

minimize the impact of these activities through careful 

location, minimal disturbance, and repeating the basic 

elements.
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1

Figure 3.19

Regional Visual Resources Management Classifications

Source: BLM, 2000; BLM, 2001.
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1 These classes represent the relative value of the visual resources. 

2

3 Classes I and II are designated as the most valued, Class III represents a moderate value, and 

4 in Class IV, visual resources are of the least value. The VRI classes provide the basis to 

5 assess visual values during the resource management planning (RMP) process conducted for 

6 all BLM-administered lands (see Figure 3.19) (BLM, 2010b). The VRI classes are considered in 

7 addition to other land uses, such as livestock grazing, recreational pursuits, and energy 

8 development when the BLM establishes its Visual Resource Management (VRM) classes during 

9 the RMP process. All public lands must be placed into one of the four VRM classes. VRM 

10 classes may or may not reflect the VRI classes, depending upon other resource considerations 

11 (i.e., a VRI Class II area could be managed as a VRM Class III, or vice versa). The text box 

12 above describes the VRM classes and the BLM objectives for each visual classification (BLM, 

13 2007c). 

14

15 The regional visual and scenic resources in the vicinity of the Ross Project area are described 

16 below, and the following section describes Ross Project-specific visual and scenic resources.

17

18 3.10.1 Regional Visual and Scenic Resources

19

20 The NSDWUMR is located within the Great Plains physiographic province, adjacent to the 

21 southern end of the Black Hills (NRC, 2009b). The northeastern corner of Wyoming, within 

22 which the Ross Project is located, is managed by the BLM’s Newcastle Field Office. Most of the 

23 surrounding area is categorized as VRM Class III, but there are some Class II areas located 

24 around Devils Tower and the Black Hills National Forest, along the Wyoming-South Dakota 

25 border (see Figure 3.19). 

26

27 Five areas of visually managed land are located within 32.2 km [20 m] of the Ross Project area, 

28 including Devils Tower (16 km [10 mi]) and the Missouri Buttes to the east of the Ross Project. 

29 Thunder Basin National Grassland (9.10 km [6 mi]) to the west and south, Keyhole State Park 

30 (18 km [11 mi]) to the southeast, and Black Hills National Forest (64 km [40 mi]) to the east 

31 (Strata, 2011a). These monuments, parks, and forests in the general vicinity of the Ross 

32 Project are indicated in Figure 3.20 (Strata, 2011a). 

33

34 President Theodore Roosevelt established Devils Tower as a national monument on September 

35 24, 1906. The Monument rises 386 m [1,267 ft] above the Belle Fourche River and is visible for 

36 at least 16 km [10 mi], as it is visible from the Ross Project area. Devils Tower and the 

37 surrounding countryside of pine forest, woodlands, and grassland attract visitors from around 

38 the world. The 545-ha [1,350-ac] park allows climbing, hiking, backpacking, and picnicking. 

39 Recreational climbing at Devils Tower has increased significantly in recent years. In 1973, there 

40 were approximately 312 climbers; currently, there are approximately 5,000 to 6,000 climbers a 

41 year (NPS, 2008). As noted above, the BLM VRM classification for Devils Tower is Class II. 

42 Beginning in 1995, climbers have enacted a voluntary closure, or a “no climbing period,” for the 

43 entire month of June as an act of respect for Native American cultural values (NPS, 2008) (see 

44 SEIS Section 3.9.1.2). 

45

46 The Black Hills National Forest (VRM Class II) encompasses streams, lakes, reservoirs, 

47 canyons and gulches, caves, varied topography, and vegetation, all of which provide habitat for 

48 an abundance of wildlife (Strata, 2011a). Keyhole State Park (VRM Class III) is home to a 

49 variety of wildlife. Keyhole Reservoir is the primary attraction to the Park and provides visitors 
DRAFT Affected Environment

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1

Figure 3.20

Roads, National Parks, National Monuments, and Forests 

in Vicinity of Ross Project Area

Source: PLIC, 2010, 

as shown in Strata, 2012a.
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1 many recreational opportunities including fishing, camping, and hiking (Strata, 2011a). The 

2 Thunder Basin National Grassland (VRM Class IV) also provides many opportunities for 

3 recreation, including fishing, hiking, and bicycling. Lush, green pastures at the Grassland 

4 provide abundant wildlife habitat. The U.S. Forest Service (USFS) manages the Grassland to 

5 conserve the natural resources of grass, water, and wildlife habitats (Strata, 2011a).

6

7 3.10.2 Ross Project Visual and Scenic Resources

8

9 The Applicant conducted a site-specific scenic-quality inventory and evaluation of the Ross 

10 Project area in October 2010, using the BLM VRI methodology (see Figure 24) (BLM, 2010b). 

11 The scenic-quality evaluation for the visual-resource study area was evaluated based on the 

12 key factors of landform, vegetation, water, color, influence of adjacent scenery, scarcity, and 

13 cultural modifications. The average scenic-quality index for the Ross Project area was 

14 determined by a rating of the scenic quality of four individual aspects (the cardinal compass 

15 points) viewed from a high point in the center of the Ross Project. The individual scores were 

16 averaged to get a scenic-quality score for the entire Ross Project area. The scenic-quality 

17 evaluation presented in Table 3.19 shows that the visual-resource evaluation rating calculated 

18 for the Ross Project area is a 10.5 out of a possible 32. More detailed information on the Ross 

19 Project scenic-quality inventory and evaluation, including photos, can be found in Appendix B. 

20

Table 3.19

Scenic-Quality

Inventory and Evaluation

(Arithmetic Average of Four Views)

Key Factor Score

Landform 2.00

Vegetation 3.00

Water 0.50

Color 2.50

Influence of Adjacent Scenery 1.25

Scarcity 2.00

Cultural Modifications -0.75

TOTAL 10.50

21

22 The BLM VRM classifications for the lands within and near the Ross Project area are shown on 

23 Figure 3.19 (BLM, 2000; BLM, 2001). The land west of the Ross Project is located in Campbell 

24 County and is categorized as VRM Class IV, while the land surrounding the Ross Project in 

25 Crook County to the east is categorized as VRM Class III. The areas studied for visual 
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1 resources include the Ross Project and the 3.2-km [2-mi] surrounding vicinity. Thus, this 

2 visual-resources area is located entirely within Crook County, and it is consequently categorized 

3 as VRM Class III. The level of change allowed by the BLM to the characteristic landscape in 

4 Class III management areas would be moderate (BLM, 2010b). 

5

6 No developed parks or recreational areas are located within the Ross Project and the 3.2-km [2-

7 mi] area around the Project (Strata, 2011a). Within these areas, there are 11 residences in 

8 addition to storage tanks; pump jacks; small maintenance buildings; public and private roads 

9 and road signage; utilities and poles (power and other utility lines); agricultural features (fences, 

10 livestock, stock tanks, and cultivated fields), and environmental-monitoring installations are 

11 prominent in the immediate foreground, and they are often noticeable in foreground views by 

12 the casual observer. 

13

14 Of the 11 residences within the study area, 4 residences have unobstructed views to the Ross 

15 Project area where the uranium-recovery facility and wellfields would be constructed, and they 

16 are in close proximity to the Ross Project in general. The closest residence is 210 m [690 ft] 

17 from the Project boundary. Of the 11 residences, 8 are located to the east of the Project area 

18 with views to the east (e.g., Devils Tower) and 3 of the 11 residences are northwest of the Ross 

19 Project area. Figure 3.21 indicates the areas where the Ross Project facility (i.e., CPP and 

20 surface impoundments) would be visible, and Figure 3.22 indicates the potential areas where 

21 light pollution from the Ross Project could impact. Photographs used to document the visual22 resource study are included in Appendix B. 

23

24 3.11 Socioeconomics

25

26 The Ross Project’s region of influence (ROI) is defined as the area within which the Ross 

27 Project’s socioeconomic impacts and benefits are reasonably anticipated to be concentrated. 

28 The Ross Project would be located in Crook County, but it is close enough to the Campbell 

29 County line that both counties are within this area of potential impacts. The ROI extends 

30 approximately 57 miles to the eastern boundary of Crook County, 41 miles to the northern 

31 boundary of Crook County, 115 miles to the western boundary of Campbell County, and 121 

32 miles to the southern boundary of Campbell County. The ROI includes all of the towns and 

33 unincorporated areas within Crook County, in which the Project’s facility and wellfields would be 

34 located and, therefore, would benefit from mineral-production tax revenues. It also includes 

35 adjacent Campbell County, which hosts the nearest, largest urban area (i.e., Gillette) and is, 

36 consequently, a potential source of labor, services, and materials to support the Ross Project. 

37

38 3.11.1 Demographics

39

40 In Campbell County, Gillette, Wyoming, is the nearest urban area to the Ross Project; it is 

41 approximately 53 km [33 mi] to the southwest of the Project. Gillette would likely serve as a 

42 regional logistics hub as well as a source of personnel and supplies for the Ross Project (Strata, 

43 2011a). Moorcroft, Wyoming, is approximately 35 km [22 mi] from the Ross Project area and 

44 could be a source of personnel as well as a place of residence for Project staff (Strata, 2011a). 

45

46 Table 3.20 presents the 2000 and 2010 population data for the potentially affected jurisdictions 

47 in the ROI. The population in Crook County was 7,083 persons as of 2010, having increased 

48 20.3 percent over 2000 levels (USCB, 2012). The population in Campbell County was 46,133 
DRAFT Affected Environment

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1

2

Figure 3.21

Viewshed Analysis of Ross Project Area

Source: Strata, 2012a.
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1

Figure 3.22

Light-Pollution Study Area

Source: Strata, 2012a.

Note: Prior to construction of the 

Ross Project, baseline monitoring 

for potential light pollution would 

be conducted at eight sites.
DRAFT Affected Environment

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1 persons as of 2010, having increased 36.9 percent over 2000 levels. In contrast, population of 

2 Wyoming as a whole increased only 14.1 percent between 2000 and 2010. Crook County is the 

3 third least populous county in Wyoming, whereas Campbell County is the third most populous.

4

Table 3.20

Populations in Crook County, Campbell County, and Wyoming

2000 and 2010

Jurisdiction 2000 2010 Change

Total 

Change 

(percent)

Annual 

Average 

Change 

(percent)

Crook County 5,887 7,083 1,196 20.3% 1.9%

Hulett 408 383 -25 -6.1% -0.6%

Moorcroft 807 1,009 202 25.0% 2.3%

Pine Haven 222 490 268 120.7% 8.2%

Sundance 1,161 1,182 21 1.8% 0.2%

Campbell County 33,698 46,133 12,435 36.9% 3.2%

Gillette 19,646 29,087 9,441 48.1% 4.0%

Wright 1,347 1,807 460 34.1% 3.0%

TOTAL ROI 39,585 53,216 13,631 34.4% 3.0%

TOTAL WYOMING 493,782 563,626 69,844 14.1% 1.3%

5 Source: USCB, 2012

6

7 Between 2000 and 2010, Gillette grew by 48.1 percent, faster than the county as whole and 

8 much faster than the entire State. This is largely attributable to the growth in the energy sector, 

9 conventional oil and gas, coal mining, and power plant construction. 

10

11 The population of Campbell County is younger than the Wyoming average, has more people per 

12 household, more households with individuals under 18 years of age, fewer households with 

13 individuals over 65 years of age, and slightly more female householders with no husband 

14 present and with their own children under 18 years old (USCB, 2012). Conversely, the 

15 population of Crook County is older than the Wyoming average with a higher median age, 

16 smaller percentage of households with individuals under 18 years of age, and a higher 

17 percentage of households with persons 65 years of age or older. 

18

19 3.11.2 Income

20

21 Per capita personal income in Crook County was $45,843 per person in 2009 and was $49,986 

22 per person in Campbell County (USBEA, 2011). By comparison, per capita income in Wyoming 
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1 was $49,887 and $40,936 in the U.S. (USBEA, 2011). Based upon the population 

2 characteristics discussed above, total personal income in the two-county area was $2.6 billion. 

3 Per capita income in Crook and Campbell counties grew at an average annual rate of 3.9 

4 percent over the 2000 to 2009 period (USBEA, 2011). In contrast, per capita income in 

5 Wyoming grew at a slightly lower rate of 3.4 percent per year, while the rate of growth in the 

6 U.S. over the same period was only 0.8 percent.

7

8 Average earnings per job in Crook County were $35,371 in 2009, having increased 2.9 percent 

9 annually since 2000. Average earnings per job in Campbell County are almost twice as high as 

10 in Crook County and were $64,612 in 2009, having increased 2.9 percent annually since 2000. 

11 In contrast, earnings per job State-wide were $46,831 and $52,358 in the U.S. for the same 

12 period.

13

14 3.11.3 Housing

15

16 As of 2010, there were 18,955 housing units in Campbell County (USCB, 2012). Of these, 

17 1,783 were vacant housing units, representing an overall vacancy rate of 9.4 percent (USCB 

18 2012). Of the 1,783 vacant units, 689 of the vacant units were for rent. In contrast, there were 

19 only 3,595 housing units in Crook County in 2010. Of these, 674 were vacant housing units, for 

20 an overall vacancy rate of 18.7 percent. Of the vacant units, only 54 vacant units were for rent.

21

22 Homeownership rates in the two Counties are high by state and national standards. Owner23 occupied units accounted for 73.3 percent of all occupied units in Campbell County and 79.3 

24 percent of all occupied units in Crook County (USCB, 2012). Homeownership for the State is 

25 69.2 percent of the population, compared to the entire U.S. where homeownership is 65.1 

26 percent of the population.

27

28 3.11.4 Employment Structure

29

30 Wyoming State Data

31

32 In October 2009, the seasonally-adjusted unemployment rate in Wyoming reached 7.4 percent 

33 for the first time since September 1987. Unemployment rates have been on the decline since 

34 that time, with the August 2011 rate reported at 5.5 percent (BLS, 2011; WDWS, 2011a).

35

36 State-wide employment grew 6.5 percent between the years 2000 and 2010 and stood at 

37 273,313 employed persons in 2010 (WDWS, 2011a). By August 2011, employment was 

38 296,424 persons, up from 277,625 persons in August 2010. 

39

40 Trade, transportation, and utilities employment represent the largest employment sector in 

41 Wyoming, with 24.0 percent of employed persons as of 2010 (WDWS, 2011a), comparable to 

42 the U.S. average of 23.0 percent. State-wide employment in the natural resources and mining 

43 sector amounted to 13.4 percent of all employment, significantly higher than the U.S. average of 

44 1.7 percent.

45

46 Crook and Campbell County Data

47

48 Employment in Crook County over the past decade has typically been in the 3,000 to 3,400 

49 range, with peak employment registered at 3,404 persons in 2008 (WDWS, 2011a). Average 
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1 annual employment in 2010 was 3,284 persons. The August 2011 monthly level is currently at 

2 3,475 persons, down slightly from the August 2010 level of 3,527 persons.

3 Unemployment rates in Crook County have been typically low by national standards, ranging 

4 from 2.7 percent to 4.3 percent over the 2000 to 2007 period, but subsequently rose to 5.8 

5 percent in both 2009 and 2010 (BLS, 2011). The unemployment rate as of August 2011 stood 

6 at a slightly reduced level of 5.0 percent, representing 175 unemployed persons at this time.

7

8 In contrast to Crook County, employment in Campbell County over the past decade has typically 

9 been in the 20,000 to 28,000 range, with peak employment registered at 28,492 persons in 

10 2009 (WDWS, 2011a). Employment dropped slightly in 2010 to 27,531 persons and August 

11 2011 levels are currently at 25,542 persons, up slightly from the comparable period in 2010, but 

12 still down from 2010 averages.

13

14 Unemployment rates in Campbell County also have been typically low by national standards, 

15 ranging from 2.0 percent to 3.7 percent over the 2000 to 2008 period, but subsequently rose to 

16 5.5 percent in 2009 and 6.0 percent in 2010 (BLS, 2011). The unemployment rate as of August 

17 2011 stood at a reduced level of 4.4 percent, representing 11,166 unemployed persons at this 

18 time.

19

20 3.11.5 Finance

21

22 The State of Wyoming does not levy a personal or corporate income tax, nor does Wyoming 

23 impose a tax on intangible assets such as bank accounts, stocks, or bonds (Strata, 2011a). In 

24 addition, Wyoming does not assess any tax on retirement income earned and received from 

25 another state. Revenues to the State of Wyoming come from three sources: taxes on mineral 

26 production, earnings on investments, and general-fund revenues. Taxes on mineral production 

27 include property taxes on the assessed value of production, severance taxes, royalties on 

28 production of State-owned minerals, and the State’s share of Federal mineral royalties. 

29 General-fund revenues include sales (at 4 percent) and use taxes, charges for sales and 

30 services, franchise taxes, and cigarette taxes. The third source of State revenues is earnings 

31 from the Wyoming Permanent Mineral Trust Fund and pooled investments. 

32

33 Cities and counties receive revenues in the form of property taxes as well as local sales and use 

34 taxes up to 2 percent, including special assessments such as capital-facilities taxes and 

35 revenue sharing from the State. Local governments are responsible for collection of property 

36 taxes, which are the primary source of funding for public schools and for municipalities, 

37 counties, and other local government units. Although Crook County has a slightly higher 

38 average mill levy than Campbell County, the mill levy is applied to a much lower evaluation, thus 

39 the property taxes raised in Crook County amounted to only a little more than 4 percent of those 

40 raised in Campbell County in FY 2010 (Strata, 2011a). 

41

42 3.11.6 Education

43

44 Kindergarten through 12th grade (K-12) public schools in Wyoming are generally organized at 

45 the county or sub-county level by school district. Campbell and Crook counties each have one 

46 public school district. Campbell County School District operates 16 elementary schools, 2 junior 

47 high schools, 2 high schools, and 1 combined junior/high school (Strata, 2011a). Crook County 

48 operates a single K-12 school, 2 elementary schools, 2 secondary (grades 7-12) schools, and 1 

49 high school (grades 8-12).
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1 Campbell County has higher school attendance rates than Wyoming as a whole in all grade 

2 levels, except college or graduate school (Strata, 2011a). The student-teacher ratio is 19.6 to 1 

3 (Campbell County School District, 2012). Crook County is below the State average at the 

4 nursery and preschool ages as well as at the kindergarten and college/graduate school levels, 

5 but well above the State average at the elementary (grades 1 – 8) and high-school levels. The 

6 student-teacher ratio is 11 to 1 (Education.com, Inc., 2012).

7

8 Wyoming also has seven community-college districts. The Northern Wyoming Community 

9 College District consists of the main campus in Sheridan, a satellite campus in Gillette, and 

10 outreach centers in Buffalo, Kaycee, and Wright. The Gillette campus is the closest post11 secondary school to the Ross Project area (Strata, 2011a).

12

13 3.11.7 Health and Social Services

14

15 Campbell County Memorial Hospital is the principal health-care provider in northeast Wyoming 

16 and offers a full range of health services, including emergency room and outpatient surgery 

17 services (Strata, 2011a). It is located approximately 65 miles from the Ross Project area. The 

18 Heptner Radiation Oncology Center was completed in 2002, and an expansion of medical 

19 oncology services was completed in 2008 to form the Cancer Care Center at Campbell County 

Memorial Hospital. An approximately 560 m2 [6,000-ft2 20 ] expansion of the Emergency 

21 Department was completed in 2009 and an extensive laboratory was completed in late 2009. 

22 The laboratory project included the first full chemistry automation line in Wyoming. A $68-

23 million expansion project on the Hospital began in June 2009, with construction of a 3.5 level, 

24 294-space parking structure adjacent to the main entrance of the Hospital. Construction began 

25 on a three-level Hospital addition, capable of supporting three additional levels, in 2010. In 

26 addition to the Hospital, Campbell County also has outpatient and walk-in clinics, surgery and 

27 rehabilitation centers, and numerous senior-residence facilities. 

28

29 The Crook County Medical Services District consists of a hospital and clinic located in 

30 Sundance, as well as clinics located in Moorcroft and Hulett. The District also provides a long31 term-care facility attached to the hospital in Sundance (Strata, 2011a). 

32

33 Sundance, Moorcroft, and Hulett have an ambulance service to cover each town and 

34 surrounding areas. Each service has Emergency Medical Technician (EMT) Intermediates, 

35 EMT Basics, and Emergency Medical Responders (EMRs) serving on their teams. Of these, 

36 Moorcroft is closest to the Ross Project area. 

37

38 A community survey of needs and services was published in June 2010 by the Campbell 

39 County CARE Board. The primary purpose of this needs assessment was to better understand 

40 the needs of people who are living in poverty in Campbell County. This survey showed that 

41 both low-income clients and agencies ranked, in order, the following services as the most highly 

42 rated needs of the County: 

43

44 ■ Emergency services

45 ■ Housing

46 ■ Health
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1 ■ Nutrition/food

2 ■ Employment and training

3

4 3.12 Public and Occupational Health and Safety

5

6 The existing pre-licensing baseline radiological conditions at the Ross Project area are 

7 discussed below.

8

9 3.12.1 Existing Site Conditions

10

11 As required by 10 CFR Part 40, Appendix A, Criterion 7, the Applicant has conducted one year 

12 of pre-licensing, pre-operational baseline radiological monitoring of the Ross Project area. It 

13 began its monitoring activities in August 2009. The resulting monitoring data establish the Ross 

14 Project area’s baseline characteristics prior to NRC licensing. This site-characterization 

15 monitoring was developed and implemented in accordance with the following NRC guidelines:

16

17 ■ NRC Regulatory Guide 4.14, Radiological Effluent and Environmental Monitoring at Uranium 

18 Mills, Revision 1 (NRC, 1980).

19 ■ NRC Regulatory Guide 3.46, Standard Format and Content of License Applications, 

20 Including Environmental Reports, For In Situ Uranium Solution Mining, Section 2.9 

21 (“Radiological Background Characteristics”) (NRC, 1982a).

22 ■ NRC Regulatory Guide 3.8, Preparation of Environmental Reports for Uranium Mills (NRC, 

23 1982b).

24 ■ NUREG–1569, Standard Review Plan For In Situ Leach Uranium Extraction License 

25 Applications (NRC, 2003).

26

27 These pre-licensing baseline radiological data represent the condition of the Ross Project area 

28 prior to development or construction of any Ross Project facility, wellfields, or any other 

29 structural improvements. These data would support future assessments of any environmental 

30 impacts that could occur as a result of the Ross Project’s construction, operation, and 

31 decommissioning, including accidental releases. That is, for most resource areas, the site32 characterization data collected by the Applicant would be used to compare and contrast any 

33 data collected during the operation of the Ross Project as well as post-operational data 

34 collected later. 

35

36 In the case of ground-water resources, however, additional post-licensing, pre-operational data 

37 would be collected (i.e., after the NRC license has been issued, but before actual uranium 

38 recovery in a wellfield is initiated, as would be required by the NRC license). This post39 licensing, pre-operational data set, which would be established for each wellfield prior to 

40 uranium recovery in that wellfield, would serve as a benchmark for the Applicant to determine 

41 whether an excursion has occurred (i.e., by way of the upper control limits (UCLs) established 

42 for that particular wellfield) and whether the ground water in a wellfield has been restored to the 

43 respective target values. These further sampling and analysis activities are discussed in SEIS 

44 Sections 2.1.1.1 and 3.5.3.
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1 As discussed in SEIS Section 3.5.3, results from ground-water site-characterization samples 

2 can be compared to the specific regulatory standards published by the EPA and the 

3 WDEQ/WQD. However, most of the analytical results discussed in this section cannot be 

4 compared easily to existing standards because the standards are specified in units other than 

5 the reported laboratory units. That is, for example, gross alpha results are reported in 

6 picoCuries/volume (pCi/L) [Bq/L] or pCi/kg [Bq/kg] (i.e., in liquid or solid matrices, respectively). 

7 This unit is a measurement of the radioactivity in a sample (such as ground water or soil). 

8 However, the units of radiation-dose standards are specified in radiation dose/unit time (Sievert 

9 or millirem [Sv or mrem]/unit time), and pCi/L or pCi/kg concentrations cannot be 

10 straightforwardly converted to mrem/unit time, which is a standard for a human’s radiation 

11 dose, without extensive modeling 

12 (including the conversion to a Total 

13 Effective Dose Equivalent [TEDE] 

14 which is one of the units used in 

15 radiation-protection regulations) 

16 (see SEIS Section 4.13). The NRC 

17 staff has taken the pre-licensing 

18 baseline data supplied by the 

19 Applicant and reviewed the 

20 modeling that the Applicant

21 performed to determine the 

22 respective total radiation dose 

23 currently present at the Ross 

24 Project area, given the 

25 radioactivity-concentration values 

26 included in Strata’s license 

27 application (Strata, 2011b; Strata, 2012b). The modeling and the pre-operational monitoring 

28 results performed by the Applicant indicate that the existing conditions at the Ross Project area 

29 do not exceed any radiation-dose guidelines or standards in the applicable regulations.

30

31 Radiation dose is a measure of the amount of ionizing energy that is deposited in a human 

32 body. Ionizing radiation is a natural component of the environment and ecosystem, and 

33 members of the public are exposed to natural radiation continuously. Radiation doses to the 

34 general public occur as a result of the radioactive materials found in the Earth’s soils, rocks, and 

35 minerals (including those in the Ross Project area). For example, radon-222 (Ra-222) is a 

36 radioactive gas that escapes into ambient air from the decay of uranium (and its progeny 

37 radium-226), which is found in most soils and rocks. Naturally occurring low levels of uranium 

38 and radium are also found in drinking water and foods. Cosmic radiation from space is another 

39 natural source of radiation. In addition to these natural sources, there are also artificial or 

40 human-made sources that contribute to the radiation dose the general public routinely receives. 

41 For example, medical diagnostic procedures using radioactive materials and x-rays are the 

42 primary human-made source of radiation the general public experiences. For comparison, the 

43 National Council for Radiation Protection estimates the average dose to the public from all 

44 natural radiation sources (terrestrial and cosmic) is 3.1 millisieverts (mSv) [310 millirem (mrem)] 

45 per year. In Wyoming, this figure is approximately 3.15 mSv/year [316 mrem/yr] (NRC, 2009b). 

How are potential radiation exposures and doses 

calculated?

Radiation dose estimates are quantified in units of either 

Sievert or rem and are often referred to in either milliSievert 

(mSv) or millirem (mrem) where 1,000 mSv = 1 Sv and 1,000 

mrem = 1 rem (Sv = 100 rem). These units are used in 

radiation protection to quantify the amount of damage to human 

tissue expected from a dose of ionizing radiation.

Person-Sv (or person-rem) is a metric used to quantify 

population radiation dose (also referred to as collective dose). 

It represents the sum of all estimated doses received by each 

individual in a population and is commonly used in calculations 

to estimate latent cancer fatalities in a population exposed to 

radiation.
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1 Pre-Licensing Baseline Radiological Conditions

2

3 Table 3.21 presents the range (i.e., the minimum and maximum values) of selected pre4 licensing baseline data for the some of the radiological parameters required by the NRC’s 

5 Regulatory Guide 4.14 (Strata, 2011b; NRC, 1980). Individual reported values for the various 

6 radiological parameters can be found in the Applicant’s TR (Strata, 2011b).

7

8 Pre-Licensing Baseline Sample Matrices, Locations, and Results

9

10 The Applicant’s pre-licensing baseline environmental-monitoring program was conducted under 

11 rigorous sampling-and-analysis procedures and quality-control methods (Strata, 2011b). During 

12 the Applicant’s environmental monitoring efforts, local ground and surface waters were sampled 

13 and analyzed as were samples of sediments, vegetation, air, wildlife, and fish. Direct gamma 

14 (“γ”) radiation was also measured. The pre-licensing baseline monitoring program included the 

15 Applicant’s obtaining samples of the following matrices at the specified locations and having the 

16 samples analyzed for the radiological parameters shown in Table 3.21. The range of the values 

17 obtained by laboratory analysis of these samples is presented in Table 3.21 as well.

18

19 Surface Water

20

21 The surface waters at the Ross Site were sampled by the Applicant at 14 locations. These 

22 locations included both the Oshoto Reservoir and two creek samples (one each from Deadman 

23 Creek and the Little Missouri River) during June 2010. Ten other water reservoirs in the Lance 

24 District were sampled as well. Three locations on the Ross Site are set up to automatically 

25 collect samples during any significant runoff events, although none occurred during the 

26 monitoring period (Strata, 2011b). In addition, intermittent and ephemeral surface-water 

27 channels were sampled when water was present. Figure 3.14 shows these locations.

28

29 Ground Water

30

31 Ground-water samples were collected during the Applicant’s pre-licensing baseline site32 characterization efforts at the Ross Project area. The samples were collected at six locations 

33 within the Ross Project area using monitoring wells screened from various horizons within the 

34 Lance/Fox Hills aquifer, on-site and nearby privately owned water supply wells. The results of 

35 all ground-water samples are more fully discussed in SEIS Section 3.5.3. Note that for samples 

36 where metals, including uranium, were to be analyzed, these samples were filtered, yielding 

37 “dissolved” concentrations in the data reported. This methodology is described in SEIS Section 

38 3.5.3.

39

40 As discussed in the Applicant’s license application and in SEIS Section 3.5.3, several ground41 water samples exceeded radiological criteria specified by the EPA for its MCLs, and some 

42 exceeded more than one of the criteria. The three MCLs are: 

43

44 ■ Uranium = 30 μg/L

45 ■ Radium-226+228 = 5 pCi/L [0.19 Bq/L]

46 ■ Gross Alpha = 15 pCi/L [0.56 Bq/L]

47
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Table 3.21

Range of Analytical Results of Pre-Licensing Baseline Samples*

All Sample Matrices

Matrix Type

Selected 

Parameters

Range 

(If Any)

of Results** (Minimum to Maximum) Units

Any 

Samples

Greater 

than 

Detection 

Limit?

Water

Surface Water†,††

Lead-210 <1 – 1.46 pCi/L Yes

Polonium-210 <1** pCi/L No

Radium-226 <0.02 – 0.46 pCi/L Yes

Radium-228 <1 – 1.52 pCi/L Yes

Thorium-230 <0.2 pCi/L No

Uraniuma <0.001 – 0.089 mg/L Yes

Gross Alpha <2 – 48.7 pCi/L Yes

Ground Water†,††

SA Zone

Lead-210 <1 pCi/L No

Polonium-210 <1 pCi/L No

Radium-226 <0.2 – 0.5 pCi/L Yes

Radium-228 <0.1 – 1.8 pCi/L Yes

Uranium <0.001 – 0.007 mg/L Yes

Gross Alpha <6 – 13.8 pCi/L Yes

SM Zone

Lead-210 <1 – 1.34 pCi/L Yes

Polonium-210 <1 pCi/L No

Radium-226 <0.2 – 3.7 pCi/L Yes

Radium-228 <0.1 – 1.3 pCi/L Yes

Uranium <0.001 – 0.004 mg/L Yes

Gross Alpha <7 – 12.2 pCi/L Yes

Ore Zone

Lead-210 <1 – 4.89 pCi/L Yes

Polonium-210 <1 – 22.9 pCi/L Yes

Radium-226 0.6 – 12.1 pCi/L Yes

Radium-228 <0.1 – 1.4 pCi/L Yes

Uranium 0.005 – 0.109 mg/L Yes

Gross Alpha <5 – 222 pCi/L Yes

1
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Table 3.21

Range of Analytical Results of Pre-Licensing Baseline Samples*

All Sample Matrices

(Continued)

Matrix Type

Selected 

Parameters

Range 

(If Any)

of Results**

(Minimum to Maximum) Units

Any 

Samples

Greater 

than 

Detection 

Limit?

DM Zone

Lead-210 <1 – 1.16 pCi/L Yes

Polonium-210 <1 pCi/L No

Radium-226 <0.2 – 0.7 pCi/L Yes

Radium-228 <0.1 – 2.2 pCi/L Yes

Uranium <0.001 – 0.013 mg/L Yes

Gross Alpha <14 – 28.3 pCi/L Yes

Piezometers in SA Zone

Lead-210 <1 pCi/L No

Polonium-210 <1 pCi/L No

Radium-226 <0.2 – 0.53 pCi/L Yes

Radium-228 <0.01 – 2.5 pCi/L Yes

Uranium <0.01 – 0.264 mg/L Yes

Gross Alpha <8.44 – 218 pCi/L Yes

Soil 

Surface and Subsurface Soils

Lead-210 <0.2 – 2.0 ± 0.7 pCi/g Yes

Radium-226 <0.005 – 14.4 ± 2.0 pCi/g Yes

Thorium-230 <0.2 – 1.29 ± 0.59 pCi/g Yes

Uranium <0.01 – 2.80 mg/kg Yes

Gross Alpha <1 – 3.6 ± 1.7 pCi/g Yes

Sediments

Lead-210 <1 – 471 ± 6.1 pCi/g Yes

Radium-226 0.8 ± 0.1 – 1.5 ± 0.1 pCi/g Yes

Thorium-230 0.39 ± 0.14 – 371 ± 58 pCi/g Yes

Uranium 0.876 – 2.24 mg/kg Yes

Gross Alpha 1.1 ± 0.4 - 2.8 ± 0.6 pCi/g Yes

1
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Table 3.21

Range of Analytical Results of Pre-Licensing Baseline Samples*

All Sample Matrices

(Continued)

Matrix Type

Selected 

Parameters

Range 

(If Any)

of Results**

(Minimum to Maximum) Units

Any 

Samples

Greater 

than 

Detection 

Limit?

Air

Particulates

Lead-210 6.25 x 10-8 – 1.14 x 10-5 pCi/L Yes

Radium-226 <Detection Limitsd pCi/L No

Thorium-230 <Detection Limits – 9.74 x 10-8 pCi/L Yes

Uranium <1.16 x 10-8 – 9.41 x 10-9 pCi/L Yes

Radon

Average Radonb 0.3 ± 0.04 – 2.0 ± 0.13 pCi/L Yes

Vegetation

Grazing Vegetation

Lead-210 3.9 ± 0.5 – 264 ± 19.1 pCi/L

Polonium-210 0.225 ± 0.51 – 23.4 ± 7.2 pCi/L

Radium-226 1.12 ± 0.08 – 1,530 ± 0.4 pCi/L

Thorium-230 <0.2 – 89.5 ± 16.4 pCi/L

Uranium 0.0017 – 8.99 mg/kg

Wetland Vegetation

Lead-210 9.07 ± 4.1 – 43.1 ± 6.1 pCi/L

Polonium-210 1.87 ± 1.7 – 5.88 ± 2.8 pCi/L

Radium-226 0.3 ± 0.1 – 11.4 ± 0.5 pCi/L

Thorium-230 <0.2 – 3.9 ± 1.5 pCi/L

Uranium 0.0005 – 0.0019 mg/kg

Hayc

Lead-210 122 ± 13 pCi/L

Polonium-210 7.61 ± 4.1 pCi/L

Radium-226 123 ± 1.1 pCi/L

Thorium-230 0.83 ± 0.20 pCi/L

Uranium 3.10 mg/kg

1
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Table 3.21

Range of Analytical Results of Pre-Licensing Baseline Samples*

All Sample Matrices

(Continued)

Matrix Type

Selected 

Parameters

Range 

(If Any)

of Results**

(Minimum to Maximum) Units

Any 

Samples

Greater 

than 

Detection 

Limit?

Vegetablec

Lead-210 2.95 ± 4.9 pCi/L

Polonium-210 2.55 ± 1.8 pCi/L

Radium-226 <0.05 pCi/L

Thorium-230 0.40 ± 0.90 pCi/L

Uranium 0.0001 mg/kg

Animal

Livestock (Beef)c

Lead-210 3.12 ± 4.8 pCi/L

Polonium-210 <1.0 pCi/L

Radium-226 0.288 ± 0.05 pCi/L

Thorium-230 <0.2 pCi/L

Uranium <0.001 mg/kg

Wildlife (Deer)c

Lead-210 13.0 ± 7.5 pCi/L

Polonium-210 3.68 ± 3.75 pCi/L

Radium-226 1.8 ± 1.5 pCi/L

Thorium-230 7.6 ± 4.2 pCi/L

Uranium <0.001 mg/kg

Fishc

Lead-210 60.4 ± 93.6 pCi/L

Polonium-210 <1.0 pCi/L

Radium-226 175 ± 15 pCi/L

Thorium-230 0.6 ± 0.6 pCi/L

Uranium 0.0160 mg/kg

Direct Gamma

Gamma Survey 5.3 – 25.3 ± 1.54 μR/hr

TLD Exposured 17.3 – 30.1 mrem/day

1 Source: Strata, 2011b.

2 Notes: See next page.
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1 Notes for Table 3.21:

2 * As suggested by NUREG-4.14.

3 ** “<” = “Less than,” where the value following the “<” value is the detection limit.

† 4 Results also discussed in SEIS Sections 3.5.1 and 3.5.3, Water Quality. †† 5 All metals concentrations in water matrices reported as dissolved concentrations 

6 (i.e., the samples were filtered).

a 7 All uranium concentrations were obtained by wet-chemistry analysis, 

8 not isotope speciation by alpha or gamma spectrometry. 

b 9 Averages are radon concentrations taken over three months at each monitoring station. c 10 One sample only.

d 11 Averages taken from approximately three-month exposures of thermo luminescent dosimeters (TLDs)

12 at each monitoring station. Each value is the “Environmental Dose,” where the Environmental Dose

13 is the Reported Dose (i.e., recorded by the TLD) minus the Transit Dose (i.e., dose 

14 received by TLD while in transit to laboratory).

15

16 Monitoring Wells and Piezometers

17

18 Six well clusters were used by the Applicant to sample ground water quarterly in 2010 (Strata, 

19 2011b). An additional four piezometers in the CPP area were also used quarterly beginning in 

20 May 2010 (a piezometer is a device that measures the pressure [more precisely, the 

21 piezometric head] of ground water at a specific location.) As described in SEIS Section 2.1.1.1, 

22 the six well clusters allowed access to four different ground-water systems in the SA, SM, OZ, 

23 and DM zones.

24

25 Drinking Water Wells

26

27 Twenty-nine local drinking water wells were also sampled quarterly, beginning in July 2009. 

28 Some of these samples could not always be obtained because some of the wells were either 

29 inaccessible during winter or non-functioning (Strata, 2011b). 

30

31 Sediments

32

33 The sediments at Oshoto Reservoir as well as those at the three surface-water monitoring 

34 stations were sampled in August 2010 (Strata, 2011b). Two cups of sediment were sampled for 

35 each location and analyzed for Uranium, Ra-226, Th-230, Pb-210, and gross alpha. 

36

37 Soil

38

39 Soil samples at the Ross Project area were obtained from 39 locations; each location was 

40 sampled at three depths (i.e., 0-30, 30-60, and 60-100 cm [0-11.8, 11.8-23.6, and 23.6-39.4 in]) 

41 (Strata, 2011b). Figure 3.23 indicates the locations of soil sampling activities. These include 

42 the three nearest residences, Strata’s Oshoto Field Office, the potential locations of the surface 

43 impoundments and the CPP, and locations over the major ore bodies where production and 

44 recovery wells could be located.

45
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1

Figure 3.23

Soil Sampling Locations at Ross Project Area

Source: Strata, 2011b.
DRAFT Affected Environment

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1 Air

2

3 Particulates

4

5 Samples of airborne particulates (e.g., dust) were collected by the Applicant at the six air6 sampling stations shown in Figure 3.24. Five of these stations commenced operation in 

7 January 2010; the sixth began operating in November 2010. The filters at each air-sampling 

8 location were collected weekly and then later composited for analysis (i.e., the filters from each 

9 sampling station were composited with the filters from only that respective station, the filters 

10 having been collected weekly over an entire quarter for a total of approximately 13 filters per 

11 composite sample) (Strata, 2011b). 

12

13 Radon

14

15 Seventeen radon-sampling locations were established by the Applicant, and the results at each 

16 were collected quarterly beginning in January 2010; two of these stations were established in 

17 mid-2010, resulting in fewer samples. The radon (i.e., a potential gaseous emission) samplers 

18 are situated at each of the particulate-sampling locations as well as in the proposed CPP and 

19 surface-impoundment areas, the four nearest residences, the former research and development 

20 site that had been explored by Nubeth, and over two ore bodies that have been identified for 

21 potential uranium recovery (Strata, 2011b). 

22

23 Vegetation

24

25 Vegetation at the Ross Project area was sampled by the Applicant in cooperation with the 

26 neighboring landowners after a field study to determine the best vegetation-sample locations 

27 was conducted in 2010. Eleven vegetation samples were ultimately collected at downwind 

28 locations and near the potential locations of the CPP and surface impoundments as well as 

29 along the major ore bodies in the mid- to late summer of 2010.

30

31 Animals

32

33 Livestock

34

35 Beef from locally raised cattle were sampled in cooperation with local landowners. Because 

36 horses are not raised in the area for human consumption, no horse-meat samples were 

37 obtained. A single beef sample was collected in July 2010 (Strata, 2011b).

38

39 Wildlife

40

41 Based on the wildlife surveys discussed in SEIS Section 3.6, the only wildlife potentially hunted 

42 at or near the Ross Project area for human consumption are deer and pronghorn antelope. One 

43 deer-meat sample was obtained from a local landowner who had hunted the deer in the

44 Project’s vicinity during the 2010 hunting season (Strata, 2011b).
DRAFT Affected Environment

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1

2

Figure 3.24

Air-Particulate Sampling Stations at Ross Project Area

Source: Strata, 2011b.
DRAFT Affected Environment

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1 Fish

2

3 A single composite sample from 99 fish that were caught at the Oshoto Reservoir was collected. 

4 Although it is reported by local landowners that fish from the Reservoir are not consumed by 

5 humans (Strata, 2011b), this sample was nonetheless submitted for analysis in September 

6 2010.

7

8 Direct (Gamma) Radiation

9

10 Gamma Field Survey

11

12 A field survey performed by a contractor for the Applicant was conducted during July 19 through 

13 22, 2010. During this survey, a total of 80,833 points were surveyed for gamma radiation 

14 (Strata, 2011a). In addition, ten soil samples were obtained for an evaluation of the potential 

15 relationship between radiation levels and radium concentrations in the corresponding soils 

16 (Strata, 2011b). The survey was performed according to the Multi-Agency Radiation Survey 

17 and Site Investigation Manual (MARSSIM) (NRC, 2000), which is the generally accepted 

18 methodology for gamma field surveys. 

19

20 Long-Term Gamma Study

21

22 A long-term study to measure long-term gamma radiation by thermo-luminescent dosimeters 

23 (TLDs) was implemented by the Applicant at the same time the radon monitoring stations were 

24 established. Ultimately, a total of 17 TLDs (and 2 controls) would be installed around the Ross 

25 Project area to measure quarterly gamma exposures. 

26

27 3.12.2 Public and Occupational Health and Safety

28

29 The exposure of members of the public to hazardous chemical is regulated by the EPA and by 

30 the State of Wyoming under a variety of statutes and regulations. The NRC, however, has the 

31 statutory responsibility, under the Atomic Energy Act (AEA), to protect public and occupational 

32 health and safety with respect to radioactive materials and radiation exposures. NRC 

33 regulations at 10 CFR Part 20 specify annual radiation dose limits to members of the public of 1 

34 mSv [100 mrem] TEDE and 0.02 mSv [2 mrem] per hour from any external radiation sources 

35 (see SEIS Section 3.12.1 for a discussion of the units of radiation dose) (10 CFR Part 20). The 

36 existing public and occupational health and safety concerns that exist at the Ross Project area 

37 today, where it currently presents minimal chemical and radiation exposures, are discussed 

38 below.

39

40 3.12.2.1 Public Health and Safety

41

42 A factor in any assessment of risks to public health and safety, including both chemical and 

43 radiation exposures, is the proximity of potentially impacted populations and the nearest 

44 receptors. As described in SEIS Section 3.2, the Ross Project area is located in a sparsely 

45 populated area of western Crook County (Strata, 2011a). The nearest community is Moorcroft, 

46 Wyoming, 35 km [22 miles] to the south, with an estimated population of approximately 1,000 

47 persons. The unincorporated town of Oshoto which is adjacent to the Ross Project area has 

48 only a very small population (approximately 50 persons). There are no residences on the 
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1 proposed Ross Project area; however, within 3 km [2 mi], there are 11 residences with 

2 approximately 30 residents. The nearest residence to the Ross Project’s boundary is 

3 approximately 210 m [690 ft] away, and the nearest residence to the CPP is about 762 m [2,500 

4 ft] away (see SEIS Sections 3.2 and 3.8).

5

6 In addition, access to the Ross Project by non-local members of the public is very limited 

7 because much of it is privately owned land; there are few public roads that enter the area; and 

8 there are no actual public attractions or recreational activities within the Ross Project area or its 

9 immediate environs. Moreover, as described in SEIS Section 3.12.1, the hazardous substances 

10 known to be present at the Ross Project area are crude oil, associated oil-contaminated water 

11 and trash, propane and methanol, and, potentially, polychlorinated biphenyls (PCBs) (Strata, 

12 2011a). Thus, there are very limited non-radiological public health and safety concerns at the 

13 Ross Project area because there are: 1) few close residential receptors, all of whom are 

14 located offsite; 2) few, if any, members of the public who can access the Project area; and 3) 

15 very few hazardous materials are present. 

16

17 With respect to the existing radiological hazards that are present at the Ross Project area, the 

18 same limitations exist as described above for nonradiological hazards: few nearby residents, no 

19 public access, and few sources of radiation exposure. The pre-licensing, site-characterization 

20 results presented in Table 3.21 indicate exposures to only common background radiation as 

21 described in SEIS Section 3.12.1. Soil results presented in Table 3.21 indicate the radionuclide 

22 concentrations in soils that are naturally occurring, including the decay products (i.e., progeny) 

23 of the naturally occurring uranium, thorium, and radon. The surface- and ground-water 

24 pathways, as described above (see SEIS Section 3.12.1), yield little if any radiation exposure to 

25 those receptors located offsite because the analytical results of surface- and ground-water 

26 samples indicate concentrations of radionuclides that are essentially at or below the respective 

27 detection limits and/or below regulatory guidelines. Finally, animal samples indicate limited 

28 concentrations of naturally occurring radionuclides. Thus, there are very limited public health 

29 and safety concerns at the Ross Project area as it is currently characterized.

30

31 3.12.2.2 Occupational Health and Safety

32

33 Nonradiological 

34

35 Occupational health and safety (i.e., industrial safety) is regulated by the State of Wyoming 

36 under the Occupational Safety and Health Administration Program. However, occupational 

37 health and safety hazards within the Ross Project area are limited by the existing land uses, 

38 which are primarily grazing, agriculture, and oil production (see SEIS Section 3.2). Known 

39 occupational health and safety concerns include common physical health and safety hazards as 

40 well as, potentially, exposures to hazardous substances. Occupational exposures could include 

41 normal, industrial, airborne hazardous substances associated with servicing equipment (e.g., 

42 vehicles); fugitive dust generated by agricultural activities and by access road use during well43 drilling activities; and various chemicals used in agriculture or during oil extraction. 

44

45 A common type of occupational hazard includes injuries and illnesses. According to the 

46 Wyoming Department of Workforce Services (WDWS), the most common lost-day injuries 

47 among mineral-extraction workers, including oil-production workers (currently the only type of 

48 consistent occupational worker present at the Ross Project area), were from strains and sprains 
DRAFT Affected Environment

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1 that often resulted from slips, trips, falls, or lifting. The Bureau of Labor Statistics (BLS) 

2 compiles annual reports of incidence rates of nonfatal occupational injuries and illnesses by 

3 industry and case types. The most recent reports include data from 2009 and 2010. For the 

4 category “uranium-radium-vanadium ore mining,” annual average employment is given as 1,000 

5 and 900 in 2009 and 2010, respectively. For both years, no total recordable cases either during 

6 work or not during work were reported (BLS, 2009; BLS, 2010). 

7

8 Radiological 

9

10 The occupational standard promulgated by the NRC is 50 mSv [5 rem] for TEDE over the entire 

11 human body (other limits pertain to exposures other than whole body). In addition, all radiation 

12 exposures are to be limited to “as low as reasonably achievable” (ALARA). However, only a few 

13 pre-construction activities are currently taking place at the Ross Project area—activities such as 

14 drillhole plugging and abandonment, monitoring well installation, and environmental monitoring 

15 sample collection by the Applicant’s personnel. As the pre-licensing baseline data demonstrate 

16 (Strata, 2011a), little radioactivity is available to come into contact with these personnel at the 

17 Ross Project area today. As a result, there is currently only a small occupational exposure to 

18 radiation (i.e., there are few personnel to be exposed and few sources of radioactivity that yield 

19 measureable doses).

20

21 3.13 Waste Management

22

23 Few wastes are currently generated at the Ross Project area, either liquid or solid. Those that 

24 are generated are described below.

25

26 3.13.1 Liquid Waste 

27

28 Sources of liquid waste generated at the Ross Project area currently include uranium29 exploration drilling, monitoring wells drilling and development, and oil-production facilities 

30 (Strata, 2011a).

31

32 Drilling the many exploration drillholes on the Ross Project generates drilling fluids and muds 

33 (i.e., cuttings). These wastes are classified as technologically enhanced, naturally occurring 

34 radioactive materials (TENORM); they are defined by EPA as “[n]aturally occurring radioactive 

35 materials that have been concentrated or exposed to the accessible environment as a result of 

36 human activities such as manufacturing, mineral extraction, or water processing” (EPA, 2008). 

37 Drilling wastes (i.e., fluid, muds, cuttings) are collected and disposed of by the Applicant in 

38 onsite excavated pits, or mud pits, that are dug for this specific purpose pursuant to the various 

39 EPA regulations governing TENORM, such as those in 40 CFR Part 192. They are allowed to 

40 evaporate and dry, and then the dried pits are reclaimed according to WDEQ/LQD 

41 requirements, usually within one construction season.

42

43 Drilling fluids and muds similar to those created during uranium-exploration drilling are also 

44 generated during the Applicant’s drilling of its preconstruction monitoring wells and drillholes 

45 that it is using to support its license application to the NRC (Strata, 2011a). These fluids are 

46 contained and evaporated in mud pits the same as those above, which are constructed adjacent 

47 to the drilling pads (Strata, 2011b). An average of 23, 000 liters [6,000 gallons] of ground water 
DRAFT Affected Environment

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along with 12 m3 [15 yd3 1 ] of drilling muds, are produced during the development and sampling of 

2 monitoring wells (Strata, 2011b). 

3

4 Ground water has also been produced during well tests conducted to characterize aquifer 

5 properties (Strata, 2011a). This TENORM water is discharged under a temporary WYPDES 

6 Permit No. WYG720229 (WDEQ/WQD, 2011). 

7

8 Crude oil and water used in its production could be present at the three oil-producing wells on 

9 the Ross Project area. These wastes are categorized by EPA as “special wastes” and are 

10 exempt from the Federal hazardous waste regulations under Subtitle C of the Resource 

11 Conservation and Recovery Action (RCRA). 

12

13 3.13.2 Solid Waste 

14

15 Few solid wastes are currently generated at the Ross Project area; no AEA-regulated wastes 

16 are currently generated. The solid wastes currently generated include predominantly 

17 miscellaneous trash from the existing agricultural and oil-production activities that currently take 

18 place at the Project area. Agricultural wastes are either disposed of at private landfills or at the 

19 local state-permitted landfill in Moorcroft; no private landfills have been identified at the Ross 

20 Project area (Strata, 2011a).

21

22 Oil-production solid wastes, such as rags contaminated by oil, propane, or methanol, are 

23 “special wastes” according to EPA regulations (i.e., they are generated in the production of 

24 crude oil) and are exempted from the EPA’s hazardous waste regulations under Subtitle C of 

25 RCRA (Strata, 2011a). There is one existing stockpile of discarded oil-production tubing that 

26 has been identified on the Ross Project area.

27

28 3.14 References

29

30 10 CFR Part 40. Title 10, “Energy,” Code of Federal Regulations, Part 40, “Domestic Licensing 

31 of Source Material,” Appendix A, “Criteria Relating to the Operation of Uranium Mills and the 

32 Disposition of Tailings or Wastes Produced by the Extraction or Concentration of Source 

33 Material from Ores Processed Primarily for their Source Material Content.” Washington, DC: 

34 Government Printing Office. 1985, as amended. 

35

36 33 CFR Part 328. Title 33, “Navigation and Navigable Waters,” Code of Federal Regulations, 

37 Part 328, “Definition of Waters of the United States.” Washington, DC: Government Printing 

38 Office. 1986, as amended.

39

40 36 CFR Part 60. Title 36, “Parks, Forests, and Public Property,” Code of Federal Regulations, 

41 Part 60, “National Register of Historic Places.” Washington, DC: Government Printing Office. 

42 1966, as amended.

43

44 36 CFR Part 800. Title 36, “Parks, Forests, and Public Property,” Code of Federal Regulations, 

45 Part 800, “Protection of Historic Properties.” Washington, DC: Government Printing Office. 

46 2004, as amended.
DRAFT Affected Environment

3-111

1 40 CFR Part 50. Title 40, “Protection of the Environment,” Code of Federal Regulations, Part 50. 

2 “National Primary and Secondary Ambient Air Quality Standards.” Washington, DC: U.S. 

3 Government Printing Office.

4

5 40 CFR Part 61. Title 40, “Protection of the Environment,” Code of Federal Regulations, Part 

6 61, “National Emission Standards for Hazardous Air Pollutants,” Subpart B, “National Emission 

7 Standards for Radon Emissions from Underground Uranium Mines.” Washington, DC: 

8 Government Printing Office. 1989, as amended.

9

10 40 CFR Part 141. Title 40, “Protection of the Environment,” Code of Federal Regulations, Part 

11 141, “National Primary Drinking Water Regulations.” Washington, DC: Government Printing 

12 Office. 1975, as amended.

13

14 40 CFR Part 143. Title 40, “Protection of the Environment,” Code of Federal Regulations, Part 

15 143, “National Secondary Drinking Water Regulations.” Washington, DC: Government Printing 

16 Office. 1970, as amended.

17

18 40 CFR Part 192. Title 40, “Protection of the Environment,” Code of Federal Regulations, Part 

19 192, “Health and Environmental Protection Standards for Uranium and Thorium Mill Tailings.” 

20 Washington, DC: Government Printing Office. 1983, as amended.

21

22 68 FR 53083. Federal Register. Volume 68, Page 53083. “Withdrawal of Proposed Rule to 

23 List the Mountain Plover as Threatened.” 

24

25 74 FR 66496. Federal Register. Volume 74, Page 66496. “Endangerment and Cause or 

26 Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act.” 

27

28 (US)ACE (U.S. Army Corps of Engineers). Interim Regional Supplement to the Corps of 

29 Engineers Wetland Delineation Manual: Great Plains Region. ERDC/EL TR-08-12. 

30 Washington, DC: USACE. March 2008. Agencywide Documents Access and Management 

31 System (ADAMS) Accession No. ML13024A331

32

33 (US)ACE. Letter from Paige Wolken, Department of the Army, Corps of Engineers, Omaha 

34 District, Wyoming Regulatory Office to Tony Simpson, Strata Energy, Inc. December 9, 2010. 

35

36 Algermissen, S. T., D. M. Perkins, P. C. Thenhaus, S. L. Hanson, and B. L. Bender. 

37 Probabilistic Estimates of Maximum Acceleration and Velocity in Rock in the Contiguous United 

38 States. U.S. Geological Survey Open File Report 82-1033, Scale 1:7,500,000. Washington, 

39 DC: U.S. Geological Survey (USGS). 1982. ADAMS Accession No. ML13022A452. 

40

41 Andres, Brad A. and Kelli L. Stone. Conservation Plan for the Mountain Plover (Charadrius 

42 montanus). Version 1.0. Manomet, MA: Manomet Center for Conservation Sciences. 2009. 

43 ADAMS Accession No. ML13022A455.

44

45 (US)BEA (U.S. Bureau of Economic Analysis, USDOC). Regional Economic Information 

46 System. Employment, earnings per job, per capita personal income estimates, Crook County, 

47 Campbell County, State of Wyoming, and United States. Washington, DC: USDOC. 2011. 
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1 BLM (Bureau of Land Management, USDOI). Visual Resource Contrast Rating. Manual 8431-

2 1. Washington, DC: USBLM. 1986. ADAMS Accession No. ML13011A379.

3

4 BLM. Record of Decision and Approved Resource Management Plan for Public Lands 

5 Administered by the Newcastle Field Office. BLM/WY/PL-00/027+1610. Newcastle, WY: 

6 USBLM. September 2000. ADAMS Accession No. ML13016A384. 

7

8 BLM. Approved Resource Management Plan for Public Lands Administered by the Bureau of 

9 Land Management, Buffalo Field Office. Buffalo, WY: USBLM. April 2001. 

10

11 BLM. Final Environmental Impact Statement and Proposed Plan Amendment for the Powder 

12 River Basin Oil and Gas Project. Volumes 1 – 4. WY-072-02-065. Buffalo, WY: USBLM. 

13 January 2003. 

14

15 BLM. Task 2 Report for the Powder River Basin Coal Review, Past and Present and 

16 Reasonably Foreseeable Development Activities. Prepared for the BLM Wyoming State 

17 Office, BLM Casper Field Office, and BLM Montana Miles City Field Office. Fort Collins, 

18 CO: ENSR Corporation. July 2005a. ADAMS Accession No. ML13016A451. 

19

20 BLM. Task 1A Report for the Powder River Basin Coal Review, Current Air Quality Conditions. 

21 Prepared for the BLM Wyoming State Office, BLM Casper Field Office, and BLM Montana Miles 

22 City Field Office. Fort Collins, CO: ENSR Corporation. September 2005b. 

23

24 BLM. Task 3A Report for the Powder River Basin Coal Review – Cumulative Air Quality 

25 Effects. Prepared for the BLM Wyoming State Office, BLM Casper Field Office, and BLM 

26 Montana Miles City Field Office. Fort Collins, CO: ENSR Corporation. February 2006. 

27

28 BLM. Final Report, Mountain Plover (Charadrius montanus) Biological Evaluation. Cheyenne, 

29 WY: USBLM, USFWS, U.S. Forest Service (USFS). March 2007a. ADAMS Accession No. 

30 ML13016A463. 

31

32 BLM. Potential Fossil Yield Classification (PFYC) System for Paleontological Resources on 

33 Public Lands. Instruction Memorandum No. 2008-009. Washington, DC: USBLM. October 

34 2007b. 

35

36 BLM. Visual Resource Management. Manual 8400. Washington, DC: USBLM. 2007c.

37 ADAMS Accession No. ML101790184.

38

39 BLM. Update of Task 3A Report for the Powder River Basin Coal Review, Cumulative Air 

40 Quality Effects for 2015. Prepared for the BLM Wyoming State Office, BLM Casper Field Office, 

41 and BLM Montana Miles City Field Office. Fort Collins, CO: ENSR Corporation. October 

42 2008a. 

43

44 BLM. Rawlins Resource Management Plan, Final Environmental Impact Statement. Rawlins, 

45 WY: USBLM. 2008b. 

46

47 BLM. Update of Task 3A Report for the Powder River Basin Coal Review, Cumulative 

48 Air Quality Effects for 2020. Prepared for the BLM Wyoming State Office, BLM Casper 
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1 Field Office, and BLM Montana Miles City Field Office. Fort Collins, CO: ENSR 

2 Corporation. December 2009a. 

3

4 BLM. Gunnison and Greater Sage-Grouse Management Considerations for Energy 

5 Development Instruction (Supplement to National Sage-Grouse Habitat Conservation Strategy). 

6 Memorandum No. 2010-071. Washington, DC: USBLM. 2010a. 

7

8 BLM. Visual Resource Inventory. Manual H–8410–1. Washington, DC: USBLM. 2010b.

9 ADAMS Accession No. ML13014A644. 

10

11 (US)BLS (U.S. Bureau of Labor Statistics). “Incidence rates of non-fatal occupational injuries 

12 and illnesses by industry and case types.” At http://www.bls.gov/iif/oshwc/osh/os/ostb2435.pdf 

13 (as of June 25, 2012). 2009. ADAMS Accession No. ML13014A700.

14

15 (US)BLS. “Incidence rates of non-fatal occupational injuries and illnesses by industry and case 

16 types”. 2010. At http://www.bls.gov/iif/oshwc/osh/os/ostb2813.pdf (as of June 25, 2012). 

17 ADAMS Accession No. ML13014A709. 

18

19 (US)BLS. Local Area Unemployment Statistics, Original Data Value, Campbell and Crook 

20 Counties, WY, 2001 to 2011. Washington, DC: USDOL. 2011. ADAMS Accession No. 

21 ML13017A248. 

22

23 Buswell, M. D. Subsurface Geology of the Oshoto Uranium Deposit, Crook County, Wyoming, 

24 M.S. Thesis, South Dakota School of Mines and Technology. Rapid City, SD: South Dakota 

25 School of Mines and Technology. May 1982. 

26

27 Campbell County School District (Campbell County School District No. 1.) Facts About 

28 Campbell County School District. Gillette, WY: Campbell County School District. 2012. 

29 ADAMS Accession No. ML13011A252.

30

31 Case, James C. and J. Annette Green. Earthquakes in Wyoming. Information Pamphlet 6. 

32 Laramie, WY: Wyoming State Geological Survey (WSGS). 2000. ADAMS Accession No. 

33 ML13017A259. 

34

35 Case, James C., Robert Kirkwood, and Rachel N. Toner. Basic Seismological Characterization 

36 for Crook County, Wyoming. Laramie, WY: WSGS. 2002. ADAMS Accession No. 

37 ML13023A274.

38

39 (US)CB (U.S. Census Bureau). “The United States Census Bureau.” 2010. At www.census.gov 

40 (as of June 25, 2012). 

41

42 (US)CB. “State and County QuickFacts, Wyoming, Crook County, Campbell County.” 2012. At 

43 http://quickfacts.census.gov/qfd/states/56000.html (as of June 25, 2012). 

44

45 Connor, Carol W. The Lance Formation—Petrography and Stratigraphy, Powder River Basin 

46 and Nearby Basins, Wyoming and Montana. U.S. Geological Survey Bulletin 1917-I. 

47 Washington, DC: USGS. 1992. ADAMS Accession No. ML13022A443.
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7

8 De Bruin, R. H. Oil and Gas Map of the Powder River Basin, Wyoming. Wyoming Geological 

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10

11 DeMallie, Raymond J. “Introduction” in Plains (Raymond J. DeMallie, Volume Editor) in 

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13 DC: Smithsonian Institution. 2001. 

14

15 Dodge, Harry W. Jr. and J. Dan Powell. Stratigraphic and Paleoenvironment Data for the 

16 Uranium-bearing Lance and Fox Hills Formations, Crook and Northern Weston Counties, 

17 Northeastern Wyoming. U.S. Geological Survey Open File Report 75-502. Washington, DC: 

18 USGS. 1975. ADAMS Accession No. ML13023A235.

19

20 Dodge, Harry W. Jr. and C. W. Spencer. “Thinning of the Fox Hills Sandstone, Crook County, 

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22 Survey, Uranium-Thorium Symposium (John S. Campbell, Editor). U.S. Geological Survey 

23 Circular 753. Washington, DC: USGS. 1977. ADAMS Accession No. ML13023A250.

24

25 (US)DOI (U.S. Department of the Interior). Bureau of Land Management, National Sage26 Grouse Habitat Conservation Strategy. Washington, DC: USDOI. November 2004. ADAMS 

27 Accession No. ML13016A323. 

28

29 (US)DOT (U.S. Department of Transportation). Highway Traffic Noise Analysis and Abatement 

30 Policy and Guidance. Washington, DC: Noise and Air Quality Branch, Office of Environment 

31 and Planning, Federal Highway Administration, USDOT. June 1995. ADAMS Accession No. 

32 ML13023A373. 

33

34 Dunlap, C. M. “The Lewis, Fox Hills and Lance Formations of Upper Cretaceous Age in the 

35 Powder River Basin, Wyoming” in Thirteenth Annual Field Conference Guidebook, Powder 

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37

38 Education.com, Inc. “Crook County School District No. 1 Student-Teacher Ratio.” 2012. 

39 Redwood City, CA: Education.com, Inc. 2012. ADAMS Accession No. ML13011A266. 

40

41 (US)EPA (U.S. Environmental Protection Agency). “Approval of the Non-Significant Revision of 

42 the State of Wyoming Underground Injection Control Program Comprised by the Aquifer 

43 Exemption of the Minnelusa Formation underlying Portions of Campbell County, WY.” Letter to 

44 Mr. Dennis Hemmer, Director, Wyoming Department of Environmental Quality, from Kerrigan G. 

45 Clough, Assistance Regional Administrator, Office of Pollution, Tribal and Assistance. 

46 December 1997. ADAMS Accession No. ML13024A059. 
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1 (US)EPA. “Protective Noise Levels: Condensed Version of EPA Levels Document.” EPA 

2 Report No. 550/9-79-100. ML13015A552. Washington DC: EPA. November 1978.

3 Ferguson, D. A Class III Cultural Resource Inventory of Strata Energy’s Proposed Ross ISR 

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5 Inc., Gillette, Wyoming. Butte, MT: GCM Services, Inc. 2010. 

6

7 Fertig, Walter. “Status Review of the Ute ladies tresses (Spiranthes diluvalis) in Wyoming” in 

8 Wyoming Natural Diversity Database. Laramie, WY: University of Wyoming. 2000. ADAMS 

9 Accession No. ML13023A267.

10

11 Fertig, Walter. “State Species Abstract: Penstemon Haydenii, Blowout Penstemon” in 

12 Wyoming Natural Diversity Database. Laramie, WY: University of Wyoming. 2008. 

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14 Academic Press, Inc. 1991. 

15

16 Frison, George C. “Hunting and Gathering Tradition: Northwestern and Central Plains” in

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19

20 (US)FWS (U.S. Fish and Wildlife Service, USDOI). Black-Footed Ferret (Mustela nigripes),

21 Five-Year Review: Summary and Evaluation. Pierre, SD: USFWS. November 2008. ADAMS 

22 Accession No. ML13024A061. 

23

24 (US)FWS. “National Wetlands Inventory.” At http://www.fws.gov/wetlands/

25 (as of June 25, 2012). April 2012a. 

26

27 (US)FWS. “Species of Concern, Birds of Conservation Concern.” At 

28 http://www.fws.gov/wyominges/Pages/Species/Species_SpeciesConcern/BirdsConsvConcern.h

29 tml (as of June 25, 2012). February 2012b. 

30

31 (US)FWS. “Migratory Bird Species of Management Concern in Wyoming.” At 

32 http://www.fws.gov/migratorybirds/Current BirdIssues/Management/BMC.html (as of June 25, 

33 2012). 2012c. 

34

35 (US)FS (U.S. Forest Service, USDOI). Final Environmental Impact Statement for the Northern 

36 Great Plains Management Plan. May 2001. At 

37 http://www.fs.fed.us/ngp/plan/feis_chpts_appx.htm (as of January 8, 2013). ADAMS Accession

38 No. ML13029A319. 

39

40 (US)GCRP (U.S. Global Change Research Program). “Regional Climate Impacts, Great 

41 Plains.” 2009. At http://www.globalchange.gov/publications/reports/scientific-assessments/us42 impacts/regional-climate-change-impacts/great-plains (as of April 12, 2012). ADAMS Accession 

43 No. ML13017A256. 

44

45 (US)GS (U.S. Geological Survey, USDOI). “Bird Checklists of the United States, Birds of 

46 Northeastern Wyoming.” August 2006. At http://www.npwrc.usgs.gov/resource/birds 

47 /chekbird/r6/newyomin.htm (as of June 25, 2012). 
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1 (US)GS. “2009 Earthquake Probability Mapping.” November 2010. At 

2 http://geohazards.usgs.gov/eqprob/2009/ (as of June 25, 2012). 

3

4 (US)GS. “Quaternary Fault and Fold Database of the United States.” February 2011. At 

5 http://earthquake.usgs.gov/hazards/qfaults/ (as of June 25, 2012). 

6

7 (US)GS. “USGS Surface-Water Data for the Nation (Historical Monthly and Annual Flow 

8 Statistics from Gaging Stations 06334000, 06334500, 06335500, 06336000, and 06337000)” 

9 April 2012a. At http://waterdata.usgs.gov/nwis/sw/ (as of June 25, 2012). 

10

11 (US)GS. “Water Quality Samples for Wyoming.” April 2012b. At http://nwis.waterdata. 

12 usgs.gov/wy/nwis/qwdata (as of June 25, 2012[b]). 

13

14 Hinaman, Kurt. Hydrogeologic Framework and Estimates of Ground-Water Volumes in Tertiary 

15 and Upper Cretaceous Hydrogeologic Units in the Powder River Basin, Wyoming. U S. 

16 Geological Survey Scientific Investigations Report 2005-5008. Prepared in Cooperation with 

17 the U.S. Bureau of Land Management. Reston, VA: USGS. 2005. ADAMS Accession No. 

18 ML13011A278.

19

20 Langford, Russell H. “The Chemical Quality of the Ground Water” in Harold A. Whitcomb and 

21 Donald A. Morris, Ground-Water Resources and Geology of Northern and Western Crook 

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23 Cooperation with the State Engineer of Wyoming. Washington, DC: Government Printing 

24 Office. 1964. 

25

26 Lisenbee, Alvis L. “Tectonic History of the Black Hills Uplift” in Thirty-Ninth Field Conference 

27 Guidebook, Eastern Powder River Basin – Black Hills. Casper, WY: WGA. 1988. ADAMS 

28 Accession No. ML13023A327. 

29

30 Merewether, Edward Allen. Stratigraphy and Tectonic Implications of Upper Cretaceous Rocks 

31 in the Powder River Basin, Northeastern Wyoming and Southeastern Montana. U.S. Geological 

32 Survey Bulletin 1917. Denver, CO: U.S. Geological Survey, Information Services. 1996. 

33 Accession No. ML13011A281. 

34

35 ND Resources. Nubeth Joint Venture, Environmental Report Supportive Information to 

36 Application for Source Material License In-Situ Solution Mining Test Site Sundance Project 

37 Crook County, Wyoming. December 1977.

38 (US)NPS (U.S. National Park Service, USDOI). “How is Devil’s Tower a Sacred Site to 

39 American Indians?” August 1994. At http://www.nps.gov/deto/historyculture/sacredsite.htm (as 

40 of June 25, 2012). 

41

42 (US)NPS. How to Apply the National Register Criteria for Evaluation. National Register Bulletin 

43 No. 15. Washington, DC: USNPS. 1997a. Accession No. ML13024A164. 

44

45 (US)NPS, Jeffery R. Hanson, and Sally Chirino. Ethnographic Overview and Assessment of 

46 Devils Tower National Monument, Wyoming. Paper 4. Washington, DC: USNPS. 1997b. 
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1 (US)NPS. Final General Management Plan/Environmental Impact Statement, Devils Tower 

2 National Monument, Crook County, WY. At http://www.nps.gov/deto/parkmgmt/devils-tower3 general-management-plan.htm (as of January 8, 2013). November 2001. 

4

5 (US)NPS. “Standing Witness: Devils Tower National Monument A History.” By J. Rodgers. 

6 http://www.nps.gov/history/history/online_books/deto/history/index.htm (as of February 24, 

7 2013). 2008.

8

9 (US)NPS. Devils Tower National Monument Frequently Asked Questions. 

10 http://www.nps.gov/deto/faqs.htm (as of January 31, 2013). December 2012.

11

12 (US)NRC (U.S. Nuclear Regulatory Commission). Radiological Effluent and Environmental 

13 Monitoring at Uranium Mills, Revision 1. Regulatory Guide 4.14. Washington, DC: NRC. 

14 1980. ADAMS Accession No. ML003739941. 

15

16 (US)NRC. Standard Format and Content of License Applications, Including Environmental 

17 Reports, For In Situ Uranium Solution Mining. Regulatory Guide 3.46. Washington, DC: NRC. 

18 1982a. ADAMS Accession No. ML003739441. 

19

20 (US)NRC. Preparation of Environmental Reports for Uranium Mills, Revision 2. Regulatory 

21 Guide 3.8. Washington, DC: NRC. October 1982b. ADAMS Accession No. ML003740211. 

22

23 (US)NRC. Final Environmental Impact Statement To Construct and Operate the Crownpoint

24 Uranium Solution Mining Project, Crownpoint, New Mexico. NUREG–1508. Washington, DC: 

25 NRC. February 1997. ADAMS Accession No. ML062830096.

26

27 (US)NRC. Standard Review Plan for In Situ Leach Uranium Extraction License Applications, 

28 Final Report. NUREG–1569. Washington, DC: NRC. June 2003. ADAMS Accession No. 

29 ML032250177. 

30

31 (US)NRC. In the Matter of Duke Energy Carolinas [and] In the Matter of Tennessee Valley 

32 Authority, Memorandum and Order. CLI-09-21. November 3, 2009a. ADAMS Accession No. 

33 ML093070690. 

34

35 (US)NRC. Generic Environmental Impact Statement for In-Situ Leach Uranium Milling 

36 Facilities, Volumes 1 and 2. NUREG–1910. Washington, DC: NRC. 2009b. ADAMS 

37 Accession Nos. ML091480244 and ML091480188. 

38

39 NRCS (Natural Resources Conservation Service, U.S. Department of Agriculture). “Soil survey 

40 geographic database for Crook County, Wyoming.” 2010. At http://soildatamart.nrcs.usda. 

41 gov/download.aspx?Survey=WY011&UseState=WY (as of April 12, 2012). 

42

43 Nuclear Dynamics. Quarterly Report, Summary of Water Quality Program. Source Material 

44 License No. SUA-1331, Docket No. 40-8663. 1978. ADAMS Accession No. ML12135A358. 

45

46 NWS (National Weather Service, National Oceanic and Atmospheric Administration, U.S. 

47 Department of Commerce [DOC]). “Wyoming Climate Summaries” for “Colony, Wyoming 
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1 (481905).” At http://www.wrcc.dri.edu/cgi-bin/cliMAIN.pl?wycolo (as of June 25, 2012). 2012. 

2 ADAMS Accession No. ML13024A342. 

3

4 Parker, Patricia and Thomas King. Guidelines for Evaluating and Documenting Traditional 

5 Cultural Properties. National Register Bulletin No. 38. Washington, DC: U.S. National Park 

6 Service (USNPS). 1998. ADAMS Accession No. ML13011A335. 

7

8 Rankl, James G. and Marlin E. Lowry. Ground-water-flow Systems in the Powder River 

9 Structural Basin, Wyoming and Montana. Water Resources Investigations Report No. 85-4229. 

10 Washington DC: USGS. 1990. ADAMS Accession No. ML13024A320

11

12 Robinson, Charles S., William J. Mapel, and Maximilian H. Bergendahl. Stratigraphy and 

13 Structure of the Northern and Western Flanks of the Black Hills Uplift, Wyoming, Montana, and 

14 South Dakota. U.S. Geological Survey Professional Paper 404. Washington, DC: USGS. 

15 1964. ADAMS Accession No. ML13024A325.

16

17 Sage-Grouse Working Group (Northeast Wyoming Sage-Grouse Working Group). “Northeast 

18 Wyoming Sage-Grouse Conservation Plan.” Cheyenne, WY: Wyoming Department of Game 

19 and Fish (WDGF). August 15, 2006. ADAMS Accession No. ML13016A281. 

20

21 Strata (Strata Energy, Inc.). Ross ISR Project USNRC License Application, Crook County, 

22 Wyoming, Environmental Report, Volumes 1, 2 and 3 with Appendices. Docket No. 40-09091. 

23 Gillette, WY: Strata. 2011a. ADAMS Accession Nos. ML110130342, ML110130344, and 

24 ML110130348. 

25

26 Strata. Ross ISR Project USNRC License Application, Crook County, Wyoming, Technical 

27 Report, Volumes 1 through 6 with Appendices. Docket No. 40-09091. Gillette, WY: Strata. 

28 2011b. ADAMS Accession Nos. ML110130333, ML110130335, ML110130314, ML110130316, 

29 ML110130320, and ML110130327. 

30

31 Strata. Ross ISR Project USNRC License Application, Crook County, Wyoming, RAI Question 

32 and Answer Responses, Environmental Report, Volume 1 with Appendices. Docket No. 40-

33 09091. Gillette, WY: Strata. 2012a. ADAMS Accession No. ML121030465. 

34

35 Strata. Ross ISR Project USNRC License Application, Crook County, Wyoming, RAI Question 

36 and Answer Responses, Technical Report, Volumes 1 and 2 with Appendices. Docket No. 40-

37 09091. Gillette, WY: Strata. 2012b. ADAMS Accession Nos. ML121020357 and 

38 ML121020361. 

39

40 (US)WRDS (U.S. Water Resources Data System) and U.S. Department of Homeland Security. 

41 “Earthquakes in Wyoming.” 2010. At http://www.wrds.uwyo.edu/wrds/wsgs/ 

42 hazards/quakes/quake.html (as of June 25, 2012). 

43

44 UW (University of Wyoming, Department of Geology and Geophysics). “Collection of Fossil 

45 Vertebrates Database.” No Date. At http://paleo.gg.uwyo.edu (as of June 25, 2012). ADAMS 

46 Accession No. ML13024A346. 
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1 UW. “Mountain Plover Data Compilation” in Wyoming Natural Diversity Database. 2010. At 

2 http://www.uwyo.edu/wyndd/data-dissemination/priority-data-comp/mtn-plover/ (as of June 25, 

3 2012). 

4

5 Whitcomb, Harold A. and Donald A. Morris. Ground-Water Resources and Geology of Northern 

6 and Western Crook County, Wyoming. U.S. Geological Survey Water-Supply Paper 1698. 

7 Washington DC: Government Printing Office. 1964. 

8

9 Whitehead, R. L. “Ground Water Atlas of the United States, Montana, North Dakota, South 

10 Dakota, Wyoming.” HA 730-I. 1996. At http://pubs.usgs.gov/ha/ha730/ch_i/index.html (as of 

11 June 25, 2012). 

12

13 WDAI (Wyoming Department of Administration and Information). “Wyoming Population 

14 Estimates and Forecasts.” June 2010. At http://eadiv.state.wy.us/pop/ (as of June 25, 2012). 

15

16 Wyoming (State of Wyoming, Office of the Governor). Greater Sage-Grouse Core Area 

17 Protection. EO No. 2011-5. Cheyenne, WY: State of Wyoming Executive Department. June 2, 

18 2011. ADAMS Accession No. ML13015A702

19

20 WDEQ/AQD (Wyoming Department of Environmental Quality/Air Quality Division). “Air Quality,” 

21 Rules and Regulations,” Chapter 2. Cheyenne, WY: WDEQ/AQD. 2010. 

22

23 WDEQ/LQD (Wyoming Department of Environmental Quality/Land Quality Division). Topsoil 

24 and Overburden. Guideline 1. Cheyenne, WY: WDEQ/LQD. November 1994. ADAMS 

25 Accession No. ML13024A064. 

26

27 WDEQ/LQD. “Noncoal In Situ Mining,” Rules and Regulations, Chapter 11. Cheyenne, WY: 

28 WDEQ/LQD. 2005a.

29

30 WDEQ/LQD. “Hydrology, Coal and Non Coal.” Guideline 8. Cheyenne, WY: WDEQ/LQD. 

31 March 2005b.

32

33 WDEQ/WQD (Wyoming Department of Environmental Quality/Water Quality Division). 

34 “Wyoming Surface Water Classification List.” At http://deq.state.wy.us/

35 wqd/watershed/surface standards/Downloads/Standards/2-3648-doc.pdf. 2001. ADAMS 

36 Accession No. ML13016A388. 

37

38 WDEQ/WQD. “Groundwater Sampling for Metals: Summary.” ML13015A691. At 

39 http://deq.state.wy.us/wqd/groundwater/downloads/CBM/Sampling%20

40 Procedures%20for%20Metals%20April6.doc%5E.pdf (as of April 26, 2005). 2005a. 

41

42 WDEQ/WQD (Wyoming Department of Environmental Quality/Water Quality Division). “Water 

43 Quality,” Rules and Regulations, Chapter 8. Cheyenne, WY: WDEQ/WQD. 2005b. 

44

45 WDEQ/WQD. “Wyoming Surface Water Quality Standards,” Rules and Regulations, Chapter 1 . 

46 Cheyenne, WY. WDEQ/WQD. 2007. ADAMS Accession No. ML13024A069. 
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1 WDEQ/WQD. Strata Energy, Inc. – Ross Disposal Injection Wellfield, Final Permit 10-263,

2 Class I Non-hazardous, Crook County, Wyoming. Cheyenne, WY: WDEQ/WQD. April 2011. 

3 ADAMS Accession No. ML111380015.

4

5 WDWS (Wyoming Department of Workforce Services). Wyoming Labor Force Trends. 

6 Laramie, WY: Research and Planning Division, WDWS. 2011a. 

7

8 WDWS. “Wyoming Nonagricultural Wage and Salary Employment, Final Benchmark 1990-2009 

9 - Preliminary Benchmark 2010.” 2011b. At http://wydoe.state.wy.us/lmi/ces/naanav9002.htm. 

10

11 WDWS (Wyoming Department of Workforce Services). “Labor and Employment,” Rules and 

12 Regulations, Chapter 11. Cheyenne, WY: WDWS. 2012. 

13

14 WGFD. A Comprehensive Wildlife Conservation Strategy for Wyoming. Cheyenne, WY: 

15 WDGF. July 2005a. ADAMS Accession No. ML13024A147. 

16

17 WGFD (Wyoming Department of Game and Fish). Avian Species of Special Concern, Native 

18 Species Status List. Buffalo, WY: WDGF. January 2005a. 

19

20 WGFD. Recommendations for Development of Oil and Gas Resources Within Important 

21 Wildlife Habitats. Version 6.0. Cheyenne, WY: WDGF. March 2010. ADAMS Accession No. 

22 ML13016A480. 

23

24 WSEO (Wyoming State Engineer’s Office). “Water Rights Database.” 2006. At 

25 http://seo.state.wy.us/wrdb/index.aspx (as of June 25, 2012). 

26

27 WYDOT (Wyoming Department of Transportation). WYDOT Vehicle Miles Book. Cheyenne: 

28 WY: WYDOT. 2011. 
DRAFT Environmental Impacts and Mitigation Measures

4-1

1 4 ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES 

2

3 4.1 Introduction

4

5 As discussed in this Supplemental Environmental Impact Statement (SEIS) Sections 2 and 3, 

6 the Generic Environmental Impact Statement (GEIS) evaluated the potential environmental 

7 impacts of in situ recovery (ISR) projects in four distinct geographic regions, including the 

8 Nebraska-South Dakota-Wyoming Uranium Milling Region (NSDWUMR), where the proposed 

9 Ross Project area is located. Four project phases were evaluated in the GEIS for each of the 

10 geographic regions (i.e., construction, operation, aquifer restoration, and decommissioning). 

11 The activities that would occur during the four project phases at the Ross Project and their 

12 timeframes are described in SEIS Section 2. Because of the similarities between the ISR 

13 projects examined in the GEIS and the proposed Ross Project, many of the conclusions found 

14 in the GEIS can be used to identify and rate the relative impacts of the Proposed Action in this 

15 SEIS. However, if the results of the GEIS’s impact analyses indicated a wide range of impacts 

16 on a particular resource area (e.g., from SMALL to LARGE), then that resource area was 

17 evaluated in greater detail within this site-specific SEIS.

18

19 The information that has been used to perform these site-specific impact analyses has been 

20 obtained from the license-application documents submitted by the Applicant to the U.S. Nuclear 

21 Regulatory Commission (NRC) in 2011 as well as subsequent information provided by the 

22 Applicant in 2012 (Strata, 2011a; Strata, 2011b; Strata, 2012a; Strata, 2012b). The NRC staff 

23 has compiled related information from publicly available sources as well (see SEIS Section 2.1). 

24 All of this information has allowed the NRC to perform site-specific assessments of the 

25 environmental impacts of the proposed Ross Project facility and wellfields, as needed, and to 

26 evaluate the measures that would successfully mitigate those impacts.

27

28 NRC established a standard of significance for its analyses of environmental impacts during the 

29 conduct of its environmental reviews, as described in the NRC guidance NUREG–1748 (NRC, 

30 2003). This standard is summarized as follows: 

31

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

33 neither destabilize nor noticeably alter any important attribute of the resource 

34 considered. 

35

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

37 important attributes of the resource considered. 

38

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

40 destabilize important attributes of the resource considered. 

41

42 This section of the SEIS analyzes the four lifecycle phases (i.e., construction, operation, aquifer 

43 restoration, and decommissioning) of the proposed Ross Project, consistent with the analytical 

44 approach used in the GEIS (NRC, 2009). This assessment is conducted for the Proposed 

45 Action and the two Alternatives (the No-Action and North Ross Project Alternatives). The 

46 impacts are organized by the environmental resource and management areas commonly 

47 examined for the satisfaction of the National Environmental Policy Act (NEPA) requirements. 

48 These areas include:
DRAFT Environmental Impacts and Mitigation Measures

4-2

 Land Use

 Transportation

 Geology and Soils

 Water Resources

(Surface and Groundwaters)

 Ecology

 Air Quality 

 Noise

 Historical, Cultural, and 

Paleontological Resources

 Visual and Scenic Resources

 Socioeconomics

 Environmental Justice

 Public and Occupational Health and Safety

(Nonradiological and Radiological)

 Waste Management

1

2 The respective mitigation measures that would moderate the identified environmental impacts 

3 are also discussed in this section for each resource and management area. Many types of 

4 mitigation measures can be considered when any particular resource or management area’s 

5 impacts are evaluated. Some of the mitigation measures that are described in this section of 

6 the SEIS include:

7

 Permit and License Requirements

 Regulatory Requirements and Standards

 Facility Design Criteria and Modifications

 Process and System Adjustments

 Engineering and Management Techniques

 Best Management Practices (BMPs)

 Standard Operating Procedures (SOPs)

 Management and Operating Plans

 Training Prerequisites

 Scheduling and Phasing Variations

8 The respective environmental impacts and associated mitigation measures identified and 

9 evaluated in this section are also summarized in Section 8, Summary of Environmental Impacts 

10 and Mitigation Measures, in Table 8.1.

11

12 4.2 Land-Use Impacts

13

14 The Proposed Action could impact local land use during all phases of the Project’s lifecycle. 

15 Potential land-use impacts could result from land disturbance during, especially, the Ross 

16 Project’s construction and decommissioning; from grazing and access restrictions; and from 

17 competing access for mineral rights. These potential impacts could be greater in the areas 

18 where there are higher percentages of private landownership. As shown in Table 2.1, the 

19 surface owners of the Ross Project area include private owners (553 ha [1,367 ac]), the State of 

20 Wyoming (127 ha [314 ac]), and the U.S. Bureau of Land Management (BLM) (16 ha [40 ac]). 

21 At the end of operation, final site reclamation would occur during decommissioning, and all 

22 lands would be returned to their current land use. These current land uses include livestock 

23 grazing, crop agriculture, and wildlife habitat. Detailed discussion of the potential environmental 

24 impacts to land use during construction, operation, aquifer restoration, and decommissioning 

25 and site restoration for the proposed Ross Project are provided in the following sections.

26

27 4.2.1 Alternative 1: Proposed Action 

28

29 Alternative 1 consists of four phases: construction, operation, aquifer restoration, and 

30 decommissioning of an ISR uranium-recovery facility and wellfields.
DRAFT Environmental Impacts and Mitigation Measures

4-3

1 4.2.1.1 Ross Project Construction

2

3 The GEIS identified potential land-use impacts during construction resulting from land 

4 disturbances and site-access restrictions that could limit other grazing, mineral extraction,

5 or recreational activities (NRC, 2009). As discussed in 

6 GEIS Section 4.4.1, potential impacts to most aspects 

7 of land use from the construction of an ISR facility 

8 would be SMALL (NRC, 2009). This is because the 

9 amount of area disturbed by the construction would be 

10 small in comparison to the available lands; the 

11 majority of the site would not be fenced; potential 

12 conflicts over mineral access would be expected to be 

13 negotiated and agreed upon; only a small portion of 

14 the available land would be restricted from grazing; 

15 and the open spaces for hunting and off-road vehicle 

16 access would be minimally impacted by the fencing 

17 associated with the ISR facility. The GEIS

18 defined land-use impacts to be SMALL when they ranged from 50 – 750 ha [120 – 1,880 ac] 

19 (NRC, 2009).

20

21 Construction-phase activities during the Proposed Action would include construction of 

22 buildings, other auxiliary structures, and surface impoundments; wells, wellfields, and pipelines; 

23 and transportation and utility infrastructure (e.g., roads and lighting). The Applicant estimates 

24 that construction activities would disturb a total of 113 ha [280 ac] of land, which represents 16 

25 percent of the Ross Project area. The impacts on specific areas of the Proposed Action by 

26 construction activities are summarized in Table 4.1.

27

Table 4.1

Summary of Land Disturbance during Construction of Proposed Action

Activity

Total Area 

Impacted by 

Proposed Action

(ha [ac])

Total Area Impacted

in the Year Preceding 

Proposed Action 

Operation

(ha [ac])

Primary

Current Use

Central Processing 

Plant 22 [55] 22 [55]

Dryland crop

production

Pasture

Wellfield Modules 65 [160] 14 [85]

Livestock grazing

Oil and gas

production

Access Roads 12 [30] 5 [12] Livestock grazing

Deep-Injection Wells 2 [5] 1 [3] Livestock grazing

Pipelines 6 [15] 2 [5] Various

Utilities 6 [15] 2 [5] Various

TOTAL ~ 113 [280] ~ 47 [116] 

28 Source: Strata, 2011a.

What are mineral rights, oil rights, and 

drilling rights?

Rights may be conferred to remove 

minerals, oil, or sometimes water that 

may be present on and under some land. 

In jurisdictions supporting such rights, 

they may be separate from other rights to 

the land. The rights to develop minerals, 

and the purchase and sale of those 

rights, are contractual matters that must 

be agreed between the parties involved.
DRAFT Environmental Impacts and Mitigation Measures

4-4

1 The Applicant would mitigate short-term impacts resulting from construction activities by 

2 phasing its activities and limiting the amount of land disturbance at any one time; promptly 

3 restoring and reseeding disturbed areas; coordinating efforts with the oil-production company 

4 currently operating within the Ross Project area (i.e., Merit Oil Company [Merit]); using existing 

5 roads wherever possible; following existing topography during access-road construction to 

6 minimize the need to cut and fill; minimizing secondary and tertiary access-road widths; and 

7 locating access roads, pipelines, and utilities in common corridors. In addition, the Applicant

8 would establish surface-use agreements with surface owners/lessees to mitigate and/or to 

9 compensate for their temporary loss of use in areas which are currently used for livestock 

10 grazing or crop production. Cultivated fields would be specifically avoided, where possible, 

11 during facility construction and wellfield installation. 

12

13 As shown in Table 2.1, of the 16 ha [40 ac] of BLM surface-administered land within the Ross 

14 Project area, 0.5 ha [1.3 ac] would be disturbed by the Proposed Action. This disturbance 

15 would take place during the construction phase. The Applicant would restrict hunting during the 

16 life of the Project in order to protect workers. Hunting and recreation are not major land use 

17 activities within the Ross Project area and there is no public access to BLM lands, therefore 

18 impacts would be minimal. 

19

20 All of the construction activities at the Ross Project would result in temporary, short-term 

21 impacts, with the current use restored following construction, except for the area where the 

22 central processing plant (CPP) and surface impoundments (i.e., the facility) would be 

23 constructed. The use of the Ross Project lands, however, would be restored after all uranium24 recovery activities have ceased. The area of surface disturbance the Applicant estimates for 

25 the Proposed Action is less than that identified in the GEIS, and no site-specific impacts have 

26 been identified for the Proposed Action that would change the magnitude of the impacts 

27 identified by the GEIS (NRC, 2009). Thus, the land-use impacts resulting from the Ross Project 

28 would be SMALL.

29

30 4.2.1.2 Ross Project Operation 

31

32 The primary land-use impact during the Ross Project’s operation would be due to the 

33 Applicant’s installing additional wellfields and its operating the processes and circuits located in 

34 the CPP; however, these impacts are generally the same as those addressed in the 

35 construction-phase analysis above. Additionally, the affected area would be reclaimed over the 

36 longer term. 

37

38 As during the construction phase, the Applicant would reduce ongoing impacts to livestock 

39 grazing by fencing less than 12 percent of the Ross Project area at any one time, including the 

40 CPP and wellfields, during active operation of the Ross Project. In addition, the Applicant would 

41 continue to work with Merit, as discussed above, so as not to impact its oil-recovery operation. 

42

43 No further land-use impacts have been identified for the Ross Project beyond those identified in 

44 the GEIS. Thus, the land-use impacts resulting from the operation of the Proposed Action 

45 would be SMALL. 
DRAFT Environmental Impacts and Mitigation Measures

4-5

1 4.2.1.3 Ross Project Aquifer Restoration

2

3 Land use impacts during aquifer restoration would be similar to those during construction, as 

4 they could involve temporary access restrictions, and are expected to be SMALL according to 

5 GEIS Section 4.4.1 (NRC, 2009). The impacts to land use during the Proposed Action’s 

6 aquifer-restoration phase would be similar to those during the construction and operation 

7 phases, and they are consistent with the GEIS. These impacts could involve temporary access 

8 restrictions, but they are expected to be few. Mitigation measures during the Proposed Action’s 

9 aquifer-restoration phase would be identical to those identified for its construction and operation. 

10 Therefore, the land-use impacts resulting from aquifer-restoration activities at the Ross Project 

11 would be SMALL. 

12

13 4.2.1.4 Ross Project Decommissioning

14

15 As discussed in GEIS Section 4.4.1, land-use impacts would temporarily increase during 

16 decommissioning and related site restoration of an ISR facility due to the additional equipment 

17 that would be used for dismantling and removal of wellfields, pipelines, and other wellfield 

18 components as well as the demolition of the processing plant itself and any surface 

19 impoundments. In addition, the reclamation of the site would involve heavy equipment and 

20 significant earth disturbance. However, these short-term impacts would not be greater than 

21 those experienced during the construction phase. Therefore, the GEIS concluded that the land22 use impacts that result from the decommissioning an ISR facility would be SMALL (NRC, 2009). 

23

24 During decommissioning, the Ross Project area would be returned to its approximate 

25 preconstruction state, including surface topography and drainage patterns. All roads and 

26 wellfields would be removed and reclaimed, unless exempted by the request of a landowner. 

27 Topsoil would be salvaged and redistributed on disturbed areas to a depth approximately equal 

28 to pre-licensing baseline conditions. Additional subsoil would be ripped as needed to minimize 

29 soil compaction prior to revegetation. Revegetation would be completed in accordance with an 

30 approved restoration plan, which would be required as part of Strata’s Permit to Mine, and a 

31 seed mix approved by WDEQ/Land Quality Division (LQD) and the landowners would be used. 

32 Seeding would be conducted by either drill or broadcast methods, as appropriate. Once 

33 vegetation has been re-established (and all radioactive materials have been removed), the 

34 Project area would be released for unrestricted use and would no longer require a license from 

35 the NRC.

36

37 The land-use impacts resulting from the decommissioning of the Proposed Action would be 

38 SMALL and the site’s restoration would ameliorate all land-use impacts caused by earlier 

39 phases of the Proposed Action. 

40

41 4.2.2 Alternative 2: No Action

42

43 Under the No-Action Alternative, the Ross Project would not be licensed and the land would 

44 continue to be available for other uses. Although limited construction activities could occur, the 

45 113 ha [280 ac] of land surface potentially disturbed during the Proposed Action would remain 

46 mostly undisturbed. No pipelines would be laid and no additional access roads would be 

47 constructed. The Applicant could continue with some preconstruction activities, such as 

48 abandonment of exploration drillholes and the collection of environmental monitoring data, but 

49 these activities would have little land use impact. 
DRAFT Environmental Impacts and Mitigation Measures

4-6

1 The current land uses of natural-resource extraction and livestock grazing would continue with 

2 no access restrictions within the Ross Project area. Impacts to current land uses from the 

3 continued oil-production activities could also occur from accidental breaks or failures in 

4 equipment and infrastructure; however, these impacts are no different than would occur whether 

5 or not the Proposed Action were to be licensed, constructed, or operated. There would be no 

6 impact from activities associated with construction and operation of the Proposed Action under 

7 the No-Action Alternative.

8

9 Under the No-Action Alternative, there would also be no impacts due to aquifer-restoration or 

10 decommissioning activities at the Ross Project area, because no wells would have been 

11 installed nor wellfields developed for uranium recovery. Thus, there would be no impact to the 

12 current land uses. There would be no impact to land use from decommissioning activities 

13 because the Ross Project would not have been licensed, constructed, or operated. No 

14 buildings would require decontamination and dismantling; no topsoil would need to be 

15 reclaimed; and no land would need to be revegetated. The land-use impacts of the No-Action 

16 Alternative would be SMALL.

17

18 4.2.3 Alternative 3: North Ross Project

19

20 Under Alternative 3, the North Ross Project would generally be the same as the Proposed 

21 Action, except that the facility (i.e., the CPP, associated buildings, and auxiliary structures as 

22 well as the surface impoundments) would be located to the north of where it would be located in 

23 the Proposed Action, as described in SEIS Section 2.1.3. This north-site facility would be 

24 located about 900 m [3,000 ft] northwest of that the Proposed Action. Construction activities 

25 would still disturb an approximate total of 113 ha [280 ac] of land, which represents 16 percent 

26 of the total Ross Project area. The impacts from each activity would be approximately the same 

27 as those summarized in Table 4.1, except that construction of the surface impoundments at the 

28 north site could require additional engineering, while the containment barrier wall (CBW) would 

29 not need to be constructed.

30

31 For Alternative 3, the CPP would not be located in an area of dry-land crop agriculture or 

32 pasture. Therefore, Alternative 3 would cause less impact to land use if the CPP and surface 

33 impoundments were to be constructed at the north site. Nonetheless, there would be an 

34 increased loss of wildlife- and livestock-grazing opportunities during the construction and 

35 operation phases of Alternative 3, just as in the Proposed Action; these impacts would result 

36 from the construction of access roads and installation of wells, pipelines, and utilities. The total 

37 land area disturbed would be essentially the same (approximately 113 ha [280 ac]). During 

38 Alternative 3’s operation and decommissioning as well as during the restoration of the 

39 underlying aquifer, this Alternative’s impacts would be the same as those discussed earlier for 

40 the Proposed Action, because the area of land-use disturbance would generally be the same. 

41 Finally, because the impacts to land use would generally be the same in Alternatives 1 and 3, 

42 the mitigation measures for Alternative 3 would be the same, as would be their effectiveness, as 

43 those described for Alternative 1. Based upon this analysis, the land-use impacts resulting from 

44 Alternative 3 would be SMALL. 

45 4.3 Transportation

46

47 The Proposed Action could impact transportation during all phases of the Project’s lifecycle. 

48 Transportation impacts would result from workers commuting to and from the Ross Project area; 
DRAFT Environmental Impacts and Mitigation Measures

4-7

1 visitors, such as regulatory agency personnel, travelling to and from the Project; from shipments 

2 to the Ross Project area of supplies, materials, and chemicals used during the uranium3 recovery and milling processes; from shipments of other materials including uranium-loaded ion4 exchange (IX) resins from future satellite areas within the Lance District (which are considered 

5 in SEIS Section 5, Cumulative Impacts) and/or other offsite ISR or waste-water treatment 

6 facilities (i.e., toll milling); and shipments of yellowcake and wastes from the Ross Project area 

7 to other, offsite facilities such as a uranium-conversion facility. Transportation impacts could 

8 also include increased fugitive dust that would be released during the increased traffic, 

9 increased traffic accidents, increased noise, and increased incidental wildlife or livestock 

10 mortalities, compared to current area conditions. Fugitive-dust impacts are evaluated as air11 quality impacts and public and occupational health impacts in SEIS Sections 4.7 and 4.13, 

12 respectively. Noise impacts are evaluated in SEIS Section 4.8. Wildlife and livestock 

13 mortalities are evaluated as potential ecological impacts in SEIS Section 4.6. Detailed 

14 discussion of the other potential environmental impacts from Project-related transportation to 

15 and from the Ross Project area during construction, operation, aquifer restoration, and 

16 decommissioning is provided in the sections below.

17

18 4.3.1 Alternative 1: Proposed Action

19

20 Alternative 1, the Proposed Action, consists of four phases: construction, operation, aquifer 

21 restoration, and decommissioning of a uranium-recovery facility and wellfields. During the 

22 Proposed Action, transportation impacts for all phases of the Ross Project would result from the 

23 increased traffic on roads compared to current (2010) levels (see Figure 4.1); these traffic 

24 increases are summarized in Table 4.2.

25

Table 4.2 

Estimated Number of Workers and Traffic Volumes for Ross Project

Project Phase

Average No.

Daily Workers

Traffic

Passenger 

Vehicles

per Day

Trucks 

per Day

Construction 200 400 24

Operation 60 120 16

Aquifer Restoration 20 40 12

Decommissioning and 

Site Restoration 90 180 10

26 Source: Strata, 2011a.

27 Note: Vehicle counts are to and from the Ross Project (two one-way trips per vehicle per day) and each assume 

28 that each worker would be in a separate passenger vehicle.
DRAFT Environmental Impacts and Mitigation Measures

4-8

Figure 4.1

Ross Project Design Components to be Decommissioned 

and Land Uses to be Restored

Source: Strata, 2012a.
DRAFT Environmental Impacts and Mitigation Measures

4-9

1 4.3.1.1 Ross Project Construction

2

3 As described in GEIS Section 4.4.2, the increase in daily traffic on most roads that would be 

4 used for construction-supply transport and workforce commutes would not be significant and, 

5 therefore, traffic-related impacts would be SMALL (NRC, 2009). Roads with the lowest average 

6 annual daily traffic volumes, such as local county roads, would have higher (i.e., MODERATE) 

7 potential impacts, particularly when the ISR facilities are experiencing peak employment (NRC, 

8 2009). The limited duration of construction activities (i.e., 12 – 18 months), suggests that 

9 impacts would be of short duration in many areas where such a facility would be sited. 

10

11 The highest traffic volumes resulting from the proposed Ross Project would occur during the 

12 construction phase of the Proposed Action because of the relatively large workforce (i.e., 200 

13 persons) and the frequent material and equipment shipments. The increased traffic is expected 

14 to be 400 passenger cars and 24 trucks per day, which, compared to 2010 levels, represents a 

15 traffic increase of approximately 400 percent on the New Haven Road south of the Ross Project 

16 area, which would be the workers’ primary route to the Project area (Strata, 2011a). This 

17 volume is higher than that assumed in the GEIS (NRC, 2009). This significant increase in traffic 

18 could result in more traffic accidents as well as wear and tear on the road surfaces. It is 

19 expected that additional road-maintenance activities would be needed. Due to the increased 

20 projected traffic volumes on the local and county roads between I-90 and the Ross Project area, 

21 the construction impacts would be MODERATE to LARGE with respect to the traffic levels and 

22 the road-surface wear and tear. 

23

24 The increase in traffic on I-90 itself would be approximately 10 percent when compared to 2010 

25 volumes. This increase to traffic on the interstate-highway system would be SMALL, and such 

26 impacts would mostly be related to increased traffic volume. However, the Interstate-highway 

27 system has been built to accommodate additional capacity and, therefore, the resulting impacts, 

28 if any, would be minor. 

29

30 As noted above, traffic impacts to local roads are expected to be greatest during the Proposed 

31 Action’s construction, and the Applicant identifies the following expected mitigation measures 

32 (Strata, 2011a):

33

34 ■ Improve signage, including speed-limit signs, on D and New Haven Roads. 

35 ■ Implement a policy to enforce speed limits for Strata employees and contractors. The 

36 Applicant and Crook County have already executed a Memorandum of Understanding 

37 (MOU) that specifies the activities that Strata would undertake to assist with speed-limit 

38 controls, among other requirements (Strata, 2011d).

39 ■ Perform a safety analysis of the county roads where increased traffic would occur. Potential 

40 enhancements could include a decreased truck speed on D and New Haven Roads, or the 

41 assignment of “daytime headlight sections” to increase safety.

42 ■ Perform routine assessments of road conditions. The MOU between the Applicant and 

43 Crook County also includes a maintenance agreement to address road-maintenance needs.

44 ■ Explore a coalition with other companies operating heavy trucks on the county roads (e.g., 

45 the haulers of bentonite from the nearby mine) to provide additional assistance to Crook 

46 County for safety and maintenance needs.
DRAFT Environmental Impacts and Mitigation Measures

4-10

1 ■ Work with Crook County to upgrade some portions of the roads by adding gravel to specially 

2 identified sections.

3 ■ Evaluate the feasibility of an employee carpooling program, or a park-and-ride system, in 

4 Gillette or Moorcroft. Alternatives could also include a van-pool system.

5 These mitigation measures would substantially reduce the transportation impacts associated 

6 with the Proposed Action’s construction; with mitigation, the impacts of transportation would be 

7 SMALL to MODERATE.

8 4.3.1.2 Ross Project Operation

9

10 As discussed in GEIS Section 4.4.2, 

11 during the operation phase at an ISR 

12 facility, the facility-related traffic 

13 volume would be unlikely to 

14 generate any significant 

15 environmental impacts above those 

16 expected during the construction 

17 phase. Dust, noise, and possible 

18 incidental wildlife- or livestock19 mortality impacts on or near a 

20 facility’s access roads could 

21 continue to occur. The GEIS 

22 concluded that the potential impacts 

23 from transportation during facility 

24 operation could range from SMALL 

25 to MODERATE (NRC, 2009).

26

27 The GEIS also assessed the potential for accidents and their consequences when the accidents 

28 involve the transportation of hazardous chemicals and radioactive materials. The GEIS 

29 recognized the potential for high consequences from a severe accident involving transportation 

30 of hazardous chemicals in a populated area. The GEIS stated that the probability of such 

31 accidents is low because of the small number of shipments, comprehensive regulatory controls, 

32 and the ISR facility operator’s use of best management practices (BMP). For radioactive 

33 material shipments (for example, yellowcake product, loaded IX resins, or radioactive wastes), 

34 compliance with transportation regulations would be expected to limit radiological risk during 

35 normal ISR operations. The GEIS concluded there would be a low radiological risk in the 

36 unlikely event of an accident. The use of emergency-response protocols would help to mitigate 

37 the consequences of severe accidents that involve the release of radioactive materials. This 

38 SEIS reviews the radiological consequences of such accidents in Section 4.13.1 (NRC, 2009).

39

40 During the operation phase, increased traffic over that in 2010 would be present due to 

41 employee traffic; shipments of process chemicals, loaded IX resins, yellowcake, and vanadium;

42 and shipments of solid, hazardous, and radioactive wastes to and from the CPP and/or 

43 wellfields. These shipments are included in the truck count in Table 4.2. Potential impacts to 

44 other resources could again occur during uranium-recovery operation, as discussed earlier. 

45 Impacts to local roads would be less significant during operation than during construction due to 

46 the lower traffic associated with facility and wellfield operation, although the traffic on these 

What are “best management practices”?

Best management practices (BMPs) are techniques, methods, 

processes, activities, or incentives that are effective at 

delivering a particular outcome. BMPs can also be defined as 

efficient and effective ways of meeting a given objective 

based on repeatable procedures that have proven themselves 

over time, such as specific standard operating procedures 

(SOPs). Well-designed BMPs combine existing managerial 

and scientific knowledge with knowledge about the resource 

being protected. The Wyoming Department of Environmental 

Quality (WDEQ) defines best practicable technology as a 

“technology-based process determined by WDEQ as 

justifiable in terms of existing performance and achievability 

(in relation to health and safety) which minimizes, to the 

extent safe and practicable, disturbances and adverse 

impacts of the operation on human or animal life, fish, wildlife, 

plant life and related environmental values.” (WDEQ, 2007, as 

cited in NRC, 2009b). 
DRAFT Environmental Impacts and Mitigation Measures

4-11

1 roads would still be double that in 2010 (Strata, 2011a). In total, the increase in anticipated 

2 traffic during the Ross Project’s operation phase is significant when compared to current levels, 

3 although there are low and manageable risks associated with yellowcake, process-chemical, 

4 and waste transportation. Consequently, the transportation impacts during the operation phase 

5 would be less significant than during construction and would nonetheless be SMALL to LARGE. 

6 However, the magnitude of these impacts would be mitigated by the same measures used 

7 during the construction phase. Thus, with mitigation, transportation impacts would be SMALL to

8 MODERATE. 

9

10 GEIS Section 4.2.2.2 as cited by GEIS Section 4.4.2.2 evaluated yellowcake transportation, and 

11 assumed shipment volumes would range from 34 – 145 yellowcake shipments per year. The 

12 Applicant estimates that there would be 75 shipments of yellowcake per year from the Ross 

13 Project based on the maximum annual production rate (i.e. including yellowcake produced from 

14 toll milling), which is within the range of the GEIS analysis (Strata, 2011a). The GEIS indicated 

15 that 145 yellowcake shipments per year from a single ISR facility could result in 0.04 and 0.003

16 cancer deaths per year, depending on the amount of yellowcake released during a 

17 transportation accident (NRC, 2009). To minimize the risk of an accident involving yellowcake 

18 transport associated with the Proposed Action, the material would be transported in accordance 

19 with U.S. Department of Transportation (USDOT), Wyoming Department of Transportation 

20 (WYDOT), and NRC regulations, managed as a “low-specific activity” (LSA) material, and 

21 shipped on exclusive-use vehicles. Only properly licensed and trained drivers would transport 

22 LSA materials. Should a transportation accident occur, the NRC concluded that the 

23 consequences of such accidents would be limited because the Applicant would develop 

24 emergency-response protocols for yellowcake and other transportation accidents. Also, 

25 shipping companies would ensure their personnel receive proper emergency-response training. 

26 Emergency-response protocols would include communication equipment and emergency-spill 

27 cleanup kits on each vehicle and at the shipping and receiving facilities (Strata, 2011a). Based 

28 on this analysis, the impacts due to a potential accident involving the transportation of 

29 yellowcake during the operations phase of the proposed Ross Project would be SMALL. 

30

31 The Applicant estimates that approximately four bulk-chemical, fuel, and other supply and 

32 material deliveries would be made per day throughout the operation phase of the Proposed 

33 Action (Strata, 2011a). This number of shipments is greater than the daily number of chemical34 supply shipments considered in GEIS Section 4.4.2 (estimated at approximately one per day); 

35 however, these shipments would be made in accordance with the applicable USDOT 

36 hazardous-materials-shipping requirements and spill response would be similar to the response 

37 for yellowcake shipments. The Applicant conducted an analysis, using the injury rate of 4.3 x 

10-7 38 per mile, to determine the risk of an injury to a member of the general public that could 

39 result from a transportation accident involving the shipment of anhydrous ammonia. The 

40 applicant found that these shipments could result in 0.002 injuries per year. The NRC staff 

41 reviewed the Applicant’s analysis and verified that reasonable input parameters were used. 

42 Chemical shipments would be conducted safely and the probability of an accident involving

43 these shipments would be SMALL. As described in GEIS Section 4.4.2.2 and 4.2.2.2, the 

44 likelihood of an incident in a populated area would be small, given the precautions that would be 

45 taken with hazardous chemical shipments. Therefore, the potential environmental impacts of 

46 accidents involving chemical transportation during Ross Project operations would be SMALL. 

47

48 The CPP is designed to process more yellowcake than is expected to be recovered at the 

49 proposed Ross Project (Strata, 2011a). The Applicant indicates that it proposes to accept 
DRAFT Environmental Impacts and Mitigation Measures

4-12

1 uranium-loaded IX resins from other ISR operations as well as, potentially, those from offsite 

2 domestic-sewage facilities as noted in SEIS Section 2.1.1. The Applicant would expect to 

3 receive four shipments of resin per day. GEIS Section 4.2.2.2 as cited in GEIS Section 4.4.2.2 

4 concluded that the potential radiological impacts of IX resins shipments would be lower than the 

5 risks from yellowcake shipments based on the less concentrated nature of the resins; the 

6 uranium being chemically bound to the resins, which would limit dispersion in the event of a 

7 spill; and the small transport distance relative to yellowcake shipments. Although the number of 

8 shipments proposed by the Applicant is higher than the one truck per day assumed in the GEIS, 

9 the other three factors evaluated in the GEIS would ensure that the probability of an accident 

10 that involves uranium-loaded IX resins would be small. Compliance with the applicable NRC 

11 and USDOT regulations for shipping IX resins would also reduce the risk of accidents involving 

12 these shipments. Therefore, the environmental impacts of accidents involving shipments of IX 

13 resins during Ross Project operations would be SMALL 

14

15 The vanadium extracted by the Applicant in the CPP’s vanadium circuit is considered a 

16 hazardous material by USDOT and would be shipped in sealed transport vehicles to an offsite 

17 processing facility (see SEIS Section 2.1.1) (Strata, 2011a) in accordance with USDOT 

18 regulations. It is anticipated that there would be 45 shipments of vanadium from the Ross 

19 Project each year. Due to the low number of shipments, the probability of an accident involving 

20 vanadium shipments would also be small. Because of the less hazardous nature of vanadium 

21 as compared with yellowcake, the environmental impacts of accidents involving shipments of 

22 vanadium would be SMALL. 

23

24 The operation of the Proposed Action would also generate radioactive wastes. These would be 

25 shipped in 208-L [55-gal] drums inside sealed roll-off containers in accordance with applicable 

26 USDOT regulations. Only five such waste shipments are anticipated during a year; given the 

27 infrequent nature of these shipments, they do not represent a significant impact to local traffic 

28 conditions or a significant increased risk of accidents. Thus, the impacts of the shipment of 

29 radioactive wastes to traffic would be SMALL. Other solid wastes would be transported to a 

30 local municipal landfill in Moorcroft, Sundance, and/or Gillette. The Applicant estimates that one 

31 trip per week would be required to remove solid waste from the Ross Project. This number 

32 would represent a SMALL impact to the local roads, both in terms of traffic volume and impacts 

33 to local road maintenance. Finally, the Applicant anticipates that there would be one shipment 

34 of hazardous wastes from the Ross Project each month. The hazardous waste is expected to 

35 include used oil, oil-contaminated soil, oily rags, used batteries, expired laboratory reagents, 

36 fluorescent light bulbs, spent solvents, and degreasers. Given the low number of shipments, 

37 this represents a SMALL impact to the local traffic and the local roads and would have SMALL 

38 environmental impacts in the case of an accident due to the small volumes generated at the 

39 Ross Project.

40

41 To mitigate transportation impacts, many of the mitigation measures instituted during the Ross 

42 Project’s construction would continue during operation. Additional mitigation measures would 

43 be implemented for the shipment of materials, such as yellowcake, uranium-loaded IX resins, 

44 and vanadium as well as solid, hazardous, and radioactive wastes. Two mitigation measures 

45 that would address all such shipments would be 1) coordination with local emergency-response 

46 personnel, and 2) the requirement that only appropriately licensed transporters would be used. 

47 The Applicant would develop a protocol, or a SOP, to provide ongoing training to local 

48 emergency-response personnel, including EMTs, firefighters, and municipal and county law49 enforcement personnel. For each type of material, specific information would be provided about 
DRAFT Environmental Impacts and Mitigation Measures

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1 the physical and chemical characteristics of the substances being shipped, the related hazards, 

2 the potential exposure pathways, and appropriate spill-response, containment, and cleanup 

3 procedures. This training would be ongoing and would include updates on a routine schedule or 

4 as new substances are transported to or from the Ross Project. All shipments would be made 

5 by appropriately licensed transporters in accordance with USDOT and WYDOT hazardous6 material regulations and requirements. 

7

8 The release of a radioactive material as a result of a transportation-related incident would 

9 prompt the activities described in USDOT’s hazardous-materials regulations at 49 Code of 

10 Federal Regulations (CFR) 171, Subpart B, “Incident Reporting [and] Notification.” Among other 

11 activities, these regulations require immediate notice of certain incidents, preparation of detailed 

12 incident reports, submission of examination reports, and assistance with investigations and 

13 special studies. Should an accident occur that results in a release of any yellowcake or other 

14 radioactive materials to the environment, the Applicant would perform a post-cleanup 

15 radiological survey of the affected area to ensure that there are no long-term hazards 

16 associated with the released radioactive material or of spill-response and cleanup activities.

17

18 4.3.1.3 Ross Project Aquifer Restoration

19

20 As discussed in GEIS Section 4.4.2, the potential transportation impacts during aquifer 

21 restoration would be equal to or less than the potential impacts during ISR facility operation 

22 (NRC, 2009). At the Ross Project, the number of uranium-recovery workers, and therefore the 

23 number of personal vehicles, would decline significantly during aquifer restoration from the 

24 construction and operation phases (from 200 to 60 to 20 workers). Thus, the potential 

25 transportation impacts discussed above for the Ross Project’s construction and operation would 

26 be reduced due to the anticipated smaller traffic volume during this phase of the Project.

27

28 Yellowcake, vanadium, and uranium-loaded IX-resin shipments could remain the same if the 

29 CPP continues to process uranium-loaded IX resins during the Ross Project wellfield’s aquifer 

30 restoration. The shipments of process chemicals would similarly depend upon whether the CPP 

31 would continue to process loaded resins after the Ross Project’s wellfields are no longer 

32 engaged in uranium recovery. Should the CPP continue to process loaded IX resins, there 

33 would not be a reduction in worker commuting as discussed above. 

34

35 However, the impacts would be similar to those during uranium-recovery operation at the Ross 

36 Project, and these would be expected to be SMALL to MODERATE due to the workforce of 60 

37 or 20 workers. Mitigation measures implemented during aquifer restoration at the Ross Project 

38 would be identical to those implemented during its construction and operation phases. 

39

40 4.3.1.4 Ross Project Decommissioning

41

42 During ISR facility decommissioning, the GEIS concluded that transportation impacts as a result 

43 of worker commutes would steadily decrease, but initially there would be a large increase in 

44 decommissioning-phase workers. GEIS Section 4.4.2 also concluded that, based on the 

45 concentrated nature of yellowcake when shipped, the longer distance of the yellowcake 

46 shipments when compared to waste shipments, and the number of shipments when compared 

47 to byproduct waste shipments, the potential radiological risks from transportation accidents 

48 involving byproduct waste shipments during decommissioning would be bounded by the 
DRAFT Environmental Impacts and Mitigation Measures

4-14

1 yellowcake transportation risks during operations. Overall, according to GEIS Section 4.4.2, 

2 transportation impacts would be SMALL (NRC, 2009). 

3

4 During the decommissioning phase of the Ross Project, the Applicant expects that the 

5 workforce would initially increase to approximately 90 workers (up from 20 workers during 

6 aquifer restoration). Traffic on the local roads would thus increase over that of the aquifer7 restoration phase, but it would still be less than half of that expected during the Proposed 

8 Action’s construction phase. Fuel shipments would increase due to the operation of heavy 

9 equipment during decommissioning activities. Little or no yellowcake or vanadium would be 

10 shipped during the decommissioning phase; however, Project decommissioning would result in 

11 an increase in shipments of radioactive and other solid wastes. The Applicant estimates that 

12 the frequency of radioactive-waste shipments would increase from the approximately 5 per year 

13 during the operation and aquifer-restoration phases, to between 100 – 200 shipments per year 

14 during the decommissioning phase (Strata, 2011a). These shipments would still be relatively 

15 infrequent compared to passenger vehicular traffic, and they would have only a small impact on 

16 traffic volume. Solid-waste shipments are expected to increase from approximately one per 

17 week during operation and aquifer restoration to about two per week during decommissioning. 

18 Hazardous-waste shipments are expected to remain unchanged at approximately one per 

19 month throughout all four Proposed Action phases. 

20

21 As anticipated in the GEIS, the potential radiological risks associated with transportation 

22 accidents involving byproduct waste shipments during decommissioning at the Ross Project 

23 would be bounded by the risks associated with transporting yellowcake during operations. The 

24 GEIS assumed that the distance between the yellowcake conversion facility and the proposed 

25 project would be greater than the distance between the waste disposal facility and the proposed 

26 project. Consistent with the GEIS, the distance from the Ross Project area to the conversion 

27 facility that would accept the yellowcake is 2,029 km [1,260 mi] whereas the byproduct waste 

28 would travel between 378 km [235 mi] to 1,610 km [1,000 mi] to a disposal facility. The GEIS 

29 also assumed that there would be up to 145 yellowcake shipments per year and 300 total 

byproduct material shipments during decommissioning (based on 4,593 m3 [6,008 yd3 30 ] of 

byproduct material generated during decommissioning and each shipment containing 15 m3 31 [20 

yd3 32 ] of byproduct material), which would result in more yellowcake shipments than byproduct 

33 material shipments overall. The Applicant estimates that there would be 75 shipments of 

yellowcake per year during operations and 3,823 m3 [5,000 yd3 34 ] of byproduct material generated 

35 during decommissioning (250 total shipments of byproduct material during decommissioning), 

36 which would also result in more yellowcake shipments than byproduct material shipments 

37 overall. 

38

39 Potential transportation impacts would be less during decommissioning than those occurring 

40 during construction; however, they would be still be SMALL to MODERATE due to the 

41 increased workforce required for decommissioning (approximately 90 workers). Mitigation 

42 measures implemented during the Proposed Action’s decommissioning would be identical to 

43 those that would be implemented during all of the other phases of the Ross Project. 

44

45 4.3.2 Alternative 2: No Action

46

47 Under the No-Action Alternative, the Ross Project would not be licensed and the land would 

48 continue to be available for other uses. However, traffic volumes and patterns would likely 

49 increase from the 2010 pre-licensing baseline conditions noted in SEIS Section 3.3 because 
DRAFT Environmental Impacts and Mitigation Measures

4-15

1 additional residences could be expected to be built near the Ross Project over time. The 

2 Applicant has projected that volumes would increase approximately 2 percent per year, even 

3 without the Ross Project’s construction and operation (Strata, 2011a). There would be no 

4 transportation of materials of any kind to or from the Ross Project to support uranium-recovery 

5 activities. There would be no transportation of either radioactive or solid wastes from the 

6 Proposed Action because the Ross Project would neither be licensed nor constructed and 

7 operated. The current transportation activities to support ongoing oil production and bentonite 

8 mining would be the same. In addition, the Applicant would continue with some preconstruction 

9 activities, such as abandonment of exploration drillholes and collection of environmental data. 

10 These activities are similar to those currently occurring at the Ross Project area, and, although 

11 short-term increases in activity could occur, these impacts would be SMALL. 

12

13 4.3.3 Alternative 3: North Ross Project

14

15 Under Alternative 3, the North Ross Project would generally be the same as the Proposed 

16 Action, except that the facility (i.e., the CPP, associated buildings, and auxiliary structures as 

17 well as the surface impoundments) would be located to the north of where it would be located in 

18 the Proposed Action, as described in SEIS Section 2.1.3. This change in facility location would 

19 cause a change in the impacts to local roads as compared to current conditions, because 

20 additional roads would be used that would not be used during the Proposed Action at the south 

21 site—most notably, the Oshoto Connection and the D Road north of the D Road/New Haven 

22 Road intersection (see Figure 2.1 in SEIS Section 2). There would likely be less localized 

23 impact to the New Haven Road, as it is anticipated that the majority of the traffic from the 

24 Proposed Action would access the Ross Project area by travelling D Road to the Oshoto 

25 Connection (Strata, 2011a). Although this change would minimize impacts to the New Haven 

26 Road, it would nevertheless cause a corresponding increase in impacts to the D Road and the 

27 Oshoto Connection as both roads are similarly constructed and maintained. Since the total 

28 traffic counts would remain the same during all phases of Alternative 3 as those for the 

29 Proposed Action, the transportation impacts would be the same as those described earlier for 

30 Alternative 1, SMALL to LARGE. As the same mitigation measures discussed for the Proposed 

31 Action would be employed for Alternative 3, the resulting transportation impacts would be 

32 SMALL to MODERATE.

33

34 4.4 Geology and Soils

35

36 4.4.1 Alternative 1: Proposed Action

37

38 Alternative 1, the Proposed Action, consists of four phases: construction, operation, aquifer 

39 restoration, and decommissioning of a uranium-recovery facility and wellfields.

40

41 4.4.1.1 Ross Project Construction 

42

43 As described in GEIS Section 4.2.3 and 4.4.3, the principal impacts to geology and soil during 

44 construction would result from disturbance of soil and surficial bedrock by construction activities. 

45 These activities include the Applicant’s clearing ground or topsoils, eliminating the vegetation 

46 that is present; cutting, filling, and grading the ground surface, preparing it for the construction of 

47 the CPP, surface impoundments, access roads, utility corridors, and wellfields; excavating and 

48 backfilling trenches for pipelines and other subsurface design components; and excavating the 

49 mud pits, CBW, and flood-control diversion channel (NRC, 2009). As the GEIS noted, the 
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1 impacts on geology and soils from construction activities depend upon local topography, surface 

2 bedrock geology (i.e., the rock immediately below the soil), and soil characteristics. The GEIS 

3 concluded that, with the implementation of appropriate BMPs, the impacts on geology and soils 

4 would be SMALL, if less than 15 percent of an ISR project’s area would be affected. As 

5 described earlier in SEIS Section 4.2, approximately 113 ha [280 ac] of land, or about 16 

6 percent of the Ross Project area, would be disturbed during the lifecycle of the project (Strata, 

7 2011b). This area is slightly larger than that identified in the GEIS; thus, a site-specific analysis 

8 is provided here.

9

10 Geology

11

12 Construction activities are not expected to encounter bedrock, except for localized impacts to 

13 the surficial bedrock by construction of the CBW. The wall would be a 0.7-m- [2-ft] wide barrier 

14 of a soil-bentonite mixture extending from the surface to at least 0.7 m- [2 ft-] into bedrock. The 

15 impacts of the CBW’s construction would be SMALL, due to the relatively small and localized 

16 effects on the bedrock below it. 

17

18 The impacts from the Applicant’s drilling and developing injection, recovery, and monitoring 

19 wells as well as installing the deep-injection wells are discussed in SEIS Section 4.5.

20

21 Soils

22

23 The impacts on soils would occur largely during the construction phase of the Proposed Action, 

24 when most of the ground disturbance takes place. Potential soils impacts include soils loss (by 

25 wind and water erosion), soils compaction, increased salinity, soils-productivity loss, and soils 

26 contamination. Surface-disturbing activities would expose the soils and subsoils at the Ross 

27 Project area and would temporarily increase the potential for soil loss because of wind and 

28 water erosion. As described in SEIS Section 3.4.2, the soils in the Ross Project area have a 

29 moderate to severe potential to be affected by wind erosion. One soil type, Vona fine sandy 

30 loam—which makes up less than 3 percent of the entire Ross Project area—has a severe 

31 potential for wind erosion. Water-erosion hazards range from negligible to moderate for the soil 

32 types found within the Ross Project area. 

33

34 Soils at the Ross Project also have the potential to become compacted, particularly during 

35 construction activities where heavy equipment is being operated. Soil compaction could result 

36 in a decrease in water infiltration, thereby increasing runoff. To decrease the potential for 

37 compaction, existing roads would be used where possible; secondary access-road widths would 

38 be minimized, and a one-way-in/one-way-out policy would be implemented by the Applicant to 

39 access wellfields. Compacted soils would be further addressed in the decommissioning plan 

40 (DP) that the Applicant would be required to submit to the NRC (Strata, 2011a). 

41

42 During preconstruction activities, the Applicant has been employing various methods of soil 

43 reclamation, according to landowner preference. These methods have included Strata’s 

44 “ripping” compacted soil with the teeth of a grader, loosening compacted soil with a disk, or 

45 simply replacing topsoil and reseeding. These techniques would continue to be refined and 

46 coordinated with WDEQ/LQD and the respective landowners during the Proposed Action. 

47

48 Saline soils are very susceptible to soil loss. Saline soils were not found on the Ross Project 

49 during the Applicant’s soil surveys. However, the use of magnesium chloride for dust control 
DRAFT Environmental Impacts and Mitigation Measures

4-17

1 could increase the salinity of the local soils (Strata, 2011a). If magnesium chloride were to be 

2 used on access roads for fugitive-dust control or if a salt and sand mixture were to be used for 

3 traction on primary access roads during the winter, the Applicant would sample the soils 

4 beneath and adjacent to access roads for salinity during the Proposed Action’s 

5 decommissioning phase. Any salt-impacted soils would be removed at that time.

6

7 Loss of topsoil and disturbance of soils could affect the soils’ structure and microbial activity. In 

8 turn, these changes could reduce soil productivity. Based upon the total anticipated disturbance 

9 area of 113 ha [280 ac] and the average topsoil depth of 0.53 m [1.7 ft], the volume of topsoil 

10 stockpiled during the life of the Proposed Action is estimated to be up to approximately 600,000 

m3 [800,000 yd3 11 ] (Strata, 2011b). This estimate could be conservatively high because most of 

12 the wellfields and access roads would be located outside of the 100-year floodplain at the Ross 

13 Project area, where topsoil would be thinner than average. This volume of topsoil would 

14 generally not be removed from access roads to and from the wellfields, and much of the topsoil 

15 would be replaced promptly after removal for pipeline and utility-corridor trenching. 

16

17 To mitigate the potential loss of top soil as well as soil productivity, topsoils would be salvaged 

18 and stockpiled for wellfield-decommissioning and site-restoration activities. Sequential wellfield 

19 decommissioning is anticipated by the Applicant; once a wellfield is depleted, it would be 

20 decommissioned and the field’s wells properly abandoned. This decommissioning would occur 

21 as each wellfield is taken out of service; it would not be delayed until the end of the entire Ross 

22 Project’s lifecycle. 

23

24 The Applicant proposes to locate a relatively large topsoil stockpile near the CPP (see Figure 

25 2.5 in SEIS Section 2.1.1) (Strata, 2011a). Any topsoils that are stripped before the 

26 construction of roads and drilling pads in the wellfields would be stockpiled in nearby piles, 

27 typically spaced approximately 600 m [2,000 ft] apart along access roads to minimize the soil 

28 compaction, fugitive dust, combustion gases, and noise associated with long topsoil hauls. 

29

30 Related mitigation measures designed to minimize soil loss, and to diminish fugitive dust (see 

31 SEIS Section 4.7.1.1) would include the Applicant: 1) constructing topsoil stockpiles on the 

32 leeward side of hills, where possible; 2) constructing topsoil stockpiles away from ephemeral33 stream channels or any other flood-prone areas; 3) avoiding construction within areas 

34 susceptible to flooding; 4) minimizing the disturbance of surface-water drainages (i.e., roads and 

35 pipelines would cross drainages perpendicular to the flow direction [as described in SEIS 

36 Section 3.4.2]); 5) wetting exposed soils during construction to minimize soil loss from wind 

37 erosion; 6) employing sediment-control BMPs, such as silt fences, sediment logs, and straw38 bale check dams in all disturbed areas; 7) implementing additional sediment-control BMPs for 

39 topsoil stockpiles, including seeding and installing a perimeter ditch and water-collection sump 

40 to trap storm water and sediment; and 8) restoring and reseeding disturbed areas as quickly as 

41 possible, typically within a single construction season (Strata, 2011a; WDEQ/LQD, 2005). Many 

42 of these BMPs are consistent with those identified by NRC in the GEIS in Section 7.4 and are 

43 commonly used at other ISR facilities (Strata, 2011a; NRC, 2009b).

44 To minimize soil-productivity impacts, the Applicant would use corresponding BMPs including 

45 several of the mitigation measures identified above to prevent soil loss. These BMPs include 

46 the Applicant 1) protecting topsoil stockpiles from wind and water erosion; 2) seeding topsoil 

47 stockpiles during inactive periods with an appropriate perennial seed mix; 3) redistributing 

48 topsoil and applying a permanent seed mix approved by WDEQ/LQD during the Proposed 
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4-18

1 Action’s decommissioning phase; and 4) using information gathered from reference areas over 

2 the long term to perform statistical, quantitative, and qualitative comparisons approved by 

3 WDEQ/LQD.

4

5 Although the subsurface would be exposed during the Applicant’s excavation of mud pits and 

6 pipeline trenches, the primary area of subsoil disturbance would be where the CPP and surface 

7 impoundments are to be constructed. The subsoils there would be disturbed by the cut, fill, and 

8 grading activities necessary to create a relatively level site and by the excavations for the 

9 surface impoundments, CBW, and flood-control diversion channel. The quantity of excess 

10 subsoils generated from construction of the CPP and surface-impoundment area is estimated to 

be approximately 60,000 m3 [80,000 yd3 11 ]. This material could be used to provide a slightly 

12 elevated and relatively level primary access road, or it could be stored in a subsoil stockpile 

13 separate from the topsoil stockpiles. 

14

15 During the Proposed Action’s construction, additional potential soil impacts could occur from the 

16 introduction of drilling fluids and muds to the soils near the recovery, injection, and monitoring 

17 wells. However, the volume of these drilling fluids would be small, and these fluids and muds 

18 would be contained within the mud pits excavated near each drillhole’s drilling pad. Other 

19 potential soil impacts could also occur from spills and leaks of fuel or lubricants from heavy20 construction equipment and passenger vehicles that would be operated during construction of 

21 the Ross Project. However, such spills and leaks would be contained and cleaned up 

22 immediately if they were to occur. Oil- or lubricant-contaminated soil would be disposed offsite 

23 in an appropriately permitted facility. 

24

25 During construction, up to five Class I deep-injection wells would be installed in aquifers 

26 approximately 2,000 m [6,400 ft] below ground surface (bgs). These wells would be used for 

27 the disposal of process solutions, including brine and excess permeate. The Applicant’s drilling 

28 of these wells and their completion and testing would be governed by the applicable 

29 Underground Injection Control (UIC) Class I Permit from WDEQ (WDEQ/WQD, 2011). Thus, 

30 the surface and subsurface area disturbed by these particular wells would be very limited. 

31

32 Therefore, the potential impacts of the Proposed Action’s construction to soils would be SMALL.

33

34 4.4.1.2 Ross Project Operation 

35

36 As described in GEIS Section 4.4.3, the potential impacts to geology and soils during the 

37 operation of an ISR facility could include: soil loss due to surface-water runoff and erosion; soil 

38 compaction as described above; increased soil salinity due to the use of magnesium chloride for 

39 dust control; soil contamination caused by spills and leaks of lixiviant, as the solution moves 

40 through pipelines between the wellfields and the CPP; transportation accidents, which could 

41 involve liquids; other accidental spills and leaks associated with waste management; and 

42 changes to the uranium-bearing formations as a result of the disposal of brine and other liquid 

43 byproduct wastes in UIC Class I deep-injection wells. The GEIS concluded that the impacts on 

44 geology and soils from an ISR operation would be SMALL.

45

46 Geology

47

48 During uranium-recovery operation, the lixiviant dissolves the uranium-mineral coatings on the 

49 sandstones in the targeted ore zone; this geochemical change in the rock would result in 
DRAFT Environmental Impacts and Mitigation Measures

4-19

1 mineralogical changes to the ore zone, but it would not affect the rock matrix nor rock structure. 

2 The thickness and depth of the ore zone at the Ross Project are similar to the ore zones 

3 evaluated in the GEIS (NRC, 2009). The GEIS concluded that it is unlikely that geochemical 

4 alteration of the ore zone would result in any compression or subsidence that would be 

5 translated to the ground surface.

6

7 Based upon historical uranium-recovery operations in the NSDWUMR, reactivation of geologic 

8 faults would not be anticipated (NRC, 2009b; Strata, 2011b). As established in SEIS Section 

9 3.4.4, earthquake activity in the area of the Ross Project is very low. Potential impacts 

10 associated with increased earthquake risk because of the operation of injection wells would be 

11 avoided by Applicant’s maintaining the injection pressure at a level that does not exceed the 

12 fracture pressure of the receiving rock formation, as specified in the WDEQ/Water Quality 

13 Division (WQD) permit. See SEIS Section 2.1 for a related discussion of how in situ uranium 

14 recovery is different than hydrofracking. 

15

16 The potential impacts from the operation of the Proposed Action to Ross Site geology would be 

17 SMALL.

18

19 Soils

20

21 During the operation of the Proposed Action, potential impacts from soil loss would be 

22 minimized by proper design and operation of surface-runoff features and implementation of 

23 BMPs, as described for those during construction. Soil compaction would be minimal during the 

24 Proposed Action’s operation, due to low density of roads across the Ross Project area. 

25 Mitigation measures to minimize soil compaction and to diminish increases in soils salinity 

26 would be the same as those identified for the construction phase of the Proposed Action. The 

27 potential for a release of yellowcake or IX resin during a transportation accident has been 

28 determined by NRC to be small; however, the magnitude of the impacts of this type of accident 

29 is described in SEIS Section 4.2 (NRC, 2009).

30

31 In the event of releases of process solutions from pipelines, module buildings, process vessels, 

32 or surface impoundments, the process-control system described in SEIS Section 2.1.1.2 would 

33 quickly alert an operator, who could then take action including a full shutdown of the leaking 

34 components as well as initiating immediate containment and cleanup. As noted in the GEIS, 

35 during 1996, the operator of the Crow Butte Uranium Project in Dawes County, Nebraska, 

36 logged 27 spill incidents of process solutions, with volumes ranging from 45 – 65,000 L [12 –

37 17,305 gal] (NRC, 2009). This potential for soil contamination at the Ross Project would be 

38 minimized by the Applicant: 1) adhering to the NRC and WDEQ design criteria for uranium39 recovery facilities; 2) designing successful spill-containment and leak-detection systems; 3) 

40 training employees on monitoring process parameters and recognizing potential upset 

41 conditions before spills or leaks occur; 4) training employees on inspection SOPs, spill-control 

42 BMPs, and a storm water pollution prevention plan (SWPPP); 5) frequently inspecting waste43 management systems and effluent-control systems; and 6) training all employees on spill 

44 detection, containment, and cleanup procedures (Strata, 2011a). Additional information on the 

45 excursion-monitoring and spill-detection systems incorporated into the design of the Ross 

46 Project is presented in SEIS Section 2.1.1 of this SEIS.

47

48 The design criteria for the Proposed Action include leak-detection capability in each wellfield 

49 module building, where an alarm inside the CPP would signal the on-duty operator that a spill 
DRAFT Environmental Impacts and Mitigation Measures

4-20

1 has occurred. (The CPP would be staffed 24 hours a day.) In addition, routine, weekly 

2 inspections of wellfield module buildings and wellheads would be conducted by Strata 

3 personnel. Such inspections would ensure that all piping and equipment, wellheads, and valve 

4 manholes are visually inspected (Strata, 2011b). Other wellfield leak-detection monitoring and 

5 control measures would include the continuous measurement of flows and pressures for 

6 injection and recovery trunk lines and feeder lines as well as the presence of leak-detection 

7 sensors in valve manholes and in the protective box around each wellhead. In addition, all 

8 pipelines would have been hydrostatically tested before they were buried, and the Applicant

9 would institute a monitoring program for leaks and other abnormalities as required by the NRC 

10 license (Strata, 2011b).

11

12 To minimize the potential for subsurface pipeline leaks, the WDEQ/WQD requirements for 

13 potable-water stream crossings would be incorporated into the design and construction of all 

14 pipeline stream crossings. These requirements include the Applicant: 1) providing a minimum 

15 of 0.6 m [2 ft] of soil cover (at the Ross Project, 1.2 – 1.8 m [4 – 6 ft] would typically be used) 

16 over the respective pipelines to guard against damage from livestock and to protect them from 

17 freezing; 2) using pipes with flexible, watertight joints, such as polyvinyl chloride (PVC) or high18 density polyethylene (HDPE); and 3) installing accessible isolation valves at both ends of water 

19 crossings so that the section could be isolated for testing or repair. 

20

21 Two levels of engineering controls would also minimize potential impacts to soils from the 

22 unintended release of process solutions within the CPP itself. The first level of protection is the 

23 primary containment accomplished by pipelines, vessels, and surface impoundments, all of 

24 which would be tested for leaks during construction. The second level of protection is the 

25 secondary containment that is provided by curbs, berms, and sumps for all chemical-storage 

26 tanks, process vessels, and all piping and equipment inside the CPP building (Strata, 2011a). 

27

28 The design and operation of the surface impoundments would also minimize the likelihood of 

29 liquid releases. The surface impoundments would include a double-liner and leak-detection 

30 system, and they would be operated so as to maintain sufficient reserve capacity to permit the 

31 Applicant to transfer the contents of a surface-impoundment cell to another in the event of a 

32 leak, in order to facilitate repair or replacement. To minimize the likelihood of releases, 

33 impoundment embankments would be monitored and inspected weekly by the Applicant in 

34 accordance with NRC-approved inspection protocols (Strata, 2011a).

35

36 Further, to minimize the potential impacts of soil contamination, such as short-term, elevated 

37 concentrations of radiological parameters and other associated chemical constituents above 

38 baseline levels, the Applicant would be required to establish immediate spill detection, 

39 response, containment, and cleanup protocols and SOPs (NRC, 2009) by its NRC license. For 

40 example, immediate spill response could include the Applicant shutting down the leaking 

41 pipeline, recovering as much of the spilled fluid as possible, and collecting samples of the 

42 impacted soils for comparison of constituent-concentration values (e.g., uranium, radium, and 

43 other indicators) to baseline conditions. Soils contaminated by spills or leaks would be removed 

44 in accordance with Criteria 6(6) of Appendix A to 10 CFR Part 40, which requires that soil 

45 concentrations not exceed background concentrations by more than 0.2 Bq/g [5 pCi/g] of 

46 radium-226, averaged over the first 15 cm [5.9 in] below the ground’s surface. Analytical tests 

47 would be required to demonstrate that no such residual contamination exists. Baseline 

48 concentrations have been established by the Applicant through its pre-licensing, site49 characterization monitoring program (see SEIS Section 3.12.1), and additional determination of 
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4-21

1 background values would have been established by a post-licensing, pre-operational monitoring 

2 program prior to major Ross Project construction. Soils contaminated by spills or leaks would 

3 be properly disposed of at an offsite properly licensed and permitted disposal facility (Strata, 

4 2011a). 

5

6 The NRC’s monitoring requirements would specify that licensees must report designated types 

7 and volumes spills to the NRC within 24 hours (NRC, 2009). These spills include those that 

8 cause unplanned contamination that meets the criteria at 10 CFR Part 40.60 as well as those 

9 spills that could cause public or occupational exposures that exceed the limits established in 10 

10 CFR Part 20, Subpart M (see SEIS Section 4.13). Additional reporting requirements could be 

11 imposed by the State or by NRC license conditions. The spill response requirements would be 

12 defined in the NRC license. All of these spill-response protocols would be implemented if other 

13 liquid radioactive or chemical materials or wastes, or if solid radiologically and/or chemically 

14 contaminated materials or wastes, were to be spilled or dispersed.

15

16 Potential impacts to the soils at the Ross Project would be mitigated by the Applicant’s 

17 implementation of BMPs and other spill-related procedures, plans, and programs that would be 

18 required in the NRC license. As noted above, all contaminated soils and sediments would be 

19 removed and disposed of according to the requirements of the 10 CFR Part 40, Appendix A. 

20 These mitigation measures would substantially minimize the impacts to the soils and sediments 

21 of the Ross Project area; these impacts would be SMALL.

22

23 4.4.1.3 Ross Project Aquifer Restoration 

24

25 As described in GEIS Section 4.4.3, aquifer restoration would impact the geology of the deep26 injection aquifers similarly to the operation of an ISR facility. With respect to ore-zone and soils, 

27 the potential for accidental spills and leaks would be similar, but less than, those described for 

28 the operation phase. Lixiviant would not be used during aquifer restoration so there would not 

29 be potential impacts to geology from dissolution of uranium and other constituents from the ore 

30 zone. As the quality of ground water from the exempted aquifer improves during restoration, the 

31 potential impacts of process-solution spills or leaks from pipes and pumps would decrease 

32 compared to potential impacts during operations. The GEIS determined that the potential 

33 impacts to geology and soils would be SMALL.

34

35 The potential impacts to Ross Project geology and soils associated with aquifer restoration at 

36 the Ross Project would be similar, but less, than those associated with its operation. The 

37 relative magnitude of impacts would be less because the concentrations of radionuclides, 

38 metals, and TDS in the water moving through the pipes, pipelines, and injection and recovery 

39 wells would be lower during aquifer restoration than during uranium-recovery operation. Also, 

40 there would less transport of uranium-bearing solutions and fewer shipments of yellowcake or 

41 vanadium; thus, less potential for spills and leaks than during operation. As previously 

42 described for the operation phase of the Ross Project, impacts to soils resulting from spills 

43 would be concentrations of radionuclides and other chemical constituents above established 

44 baseline or background values, but these elevated concentrations would be eliminated upon 

45 spill cleanup. Thus, the potential impacts of the Proposed Action’s aquifer restoration to 

46 geology and soils would be SMALL.
DRAFT Environmental Impacts and Mitigation Measures

4-22

1 4.4.1.4 Ross Project Decommissioning

2

3 GEIS Section 4.4.3 described the activities associated with the decommissioning of an ISR 

4 facility, including decontamination of surfaces, dismantling of process components and 

5 associated structures, demolishing buildings and other structures, removal of buried pipelines, 

6 and plugging and abandonment of wells and wellfield components (NRC, 2009). The GEIS 

7 determined that most of the impacts to geology and soils during the decommissioning phase 

8 would be short-term and SMALL. In fact, because the goal of decommissioning and site 

9 restoration is to restore, to the extent practical, the environment to preconstruction conditions

10 through activities such as redistributing, seeding, and contouring soil that would have been 

11 stockpiled during the earlier phases of the Ross Project, the overall long-term impacts to 

12 geology and soils would be SMALL (NRC, 2009).

13

14 Geology

15

16 The potential impacts to the geology of the ore zone at the Proposed Action would depend upon 

17 the density of plugged and abandoned drillholes and wells. At the end of the life of the Ross 

18 Project, the wellfields (whether recently operated or decommissioned some time ago) would 

19 contain approximately 3,000 drillholes and wells; these would include those drillholes from 

20 Strata’s ore-zone delineation efforts and geotechnical investigations, ground-water monitoring 

21 wells used for site characterization, the injection and recovery wells from uranium-recovery 

22 activities, and Nubeth Joint Venture (Nubeth) drillholes and wells. This would represent an 

23 average density of approximately 4.3 wells/ha [1.7 wells/ac]. All of these drillholes and wells 

24 would be properly abandoned by the Applicant with concrete or a similar material. Each 

25 drillhole and well would be required to be filled with a concrete plug up to 15 cm [6 in] in 

26 diameter, through the entire depth of the drillhole or well (WDEQ/LQD, 2005). The density of 

27 these concrete plugs is not great enough to alter the geology of the ore zone nor the 

28 surrounding stratigraphy. As described in SEIS Section 2.1.1.1, well-abandonment records 

29 would be maintained onsite at the Ross Project until termination of its NRC license. The 

30 impacts to ground water from improperly abandoned drillholes and wells are discussed in SEIS 

31 Section 4.5.

32 Potential impacts to the geology of the deep-injection aquifers (i.e., the Flathead and Deadwood 

33 Formations) would also be similar, but have less magnitude, than during the aquifer-restoration 

34 phase, because there would be only minimal volumes (less than 38 L/min [10 gal/min]) of liquid 

35 byproduct wastes injected into the Class I deep-disposal wells during the decommissioning 

36 phase. 

37

38 The surficial bedrock would be affected locally by the actions necessary to breach the CBW to 

39 re-establish aquifer flow. The potential impacts from these relatively small and local effects on 

40 bedrock beneath the CBW would be SMALL as would all impacts related to geology.

41

42 Soils

43

44 The potential impacts to Ross Project area soils during the decommissioning of the Proposed 

45 Action would result from activities associated with land reclamation and site restoration, 

46 including the excavation and cleanup of contaminated soils. These decommissioning impacts 

47 would be similar to those resulting from construction of the Proposed Action. The BMPs, SOPs, 

48 and other mitigation measures described earlier for the construction and operation phases 
DRAFT Environmental Impacts and Mitigation Measures

4-23

1 would continue to be implemented. Thus, the potential impacts from decommissioning activities 

2 to the local soils would be SMALL.

3

4 4.4.2 Alternative 2: No Action 

5

6 Under the No-Action Alternative, the Ross Project would not be licensed and the land would 

7 continue to be available for other uses. However, until that decision is made by the NRC, the 

8 impacts of soils compaction and soils loss by heavy equipment and vehicular traffic across the 

9 Ross Project area could occur during the Applicant’s continuing conduct of: 1) different types of 

10 surveys (e.g., continued ecological surveys); 2) boring of exploration and geotechnical drillholes; 

11 3) drilling and monitoring of all types of ground-water wells; 4) locating and abandoning Nubeth 

12 drillholes and wells; and 5) installing and observing surface-water and meteorological monitoring 

13 stations. 

14

15 As of August 2011, the Applicant had drilled and then plugged approximately 612 holes it 

16 installed during site characterization, geotechnical investigation, and ore-zone delineation; an 

17 additional 51 were also drilled and are now used as pre-licensing site-characterization ground18 water monitoring wells. The Applicant has also located and properly abandoned 55 Nubeth 

19 drillholes. Under the No-Action Alternative, the 51 drillholes would need to be responsibly 

20 abandoned by the Applicant, plugging the full depth of the drillhole or well with concrete. 

21 However, the potential impacts of all of these preconstruction and current activities would be 

22 short-term, and the related traffic over the Ross Site area would be low density and minimal. 

23 Thus, neither the geology nor the soils would sustain significant impacts; the impacts to the 

24 geology and soils as a result of Alternate 2 would be SMALL.

25

26 4.4.3 Alternative 3: North Ross Project

27

28 Under Alternative 3, the North Ross Project would generally be the same as the Proposed 

29 Action, except that the facility (i.e., the CPP, associated buildings, and auxiliary structures as 

30 well as the surface impoundments) would be located to the north of where it would be located in 

31 the Proposed Action, as described in SEIS Section 2.1.3. The geology and soils at the north 

32 site are similar, but there are a few important differences. The most important difference is that 

33 the north site slopes to the southeast at a grade of 5 – 15 percent, where the slope at the 

34 Proposed Action’s facility location, the south site, has a significant percentage of ground surface 

35 with less than 1 percent slope. Given that the cells in the surface impoundments have 

36 approximate dimensions of 75 m x 165 m [250 ft x 540 ft], significant additional grading would 

37 be necessary to construct the surface impoundments at the north site as compared to the south 

38 site’s location. Also, given that the use of above-grade embankments (to minimize the volume 

39 of release during a catastrophic failure) should be minimized from engineering and environment40 protection points of view, then the maximum depth of excavation to create each impoundment at 

41 the north site would be on the order of 4 – 12 m [13 – 40 ft], with an impoundment depth of 4.6 

42 m [15 ft] and slopes of 5 – 15 percent. It is estimated that the north site would require the 

43 grading of an additional 0.4 – 1.2 ha [1 – 3 ac] to accommodate the sloping site. 

44

45 The additional construction effort associated with these deeper cuts and larger disturbed areas 

46 would result in greater soils impacts than those resulting from Alternative 1, the Proposed 

47 Action. In addition, these deep cuts would likely encounter bedrock within 1.5 – 7.5 m [5 – 25 

48 ft], increasing the cost and complexity of the construction activities. Embankments could reduce 
DRAFT Environmental Impacts and Mitigation Measures

4-24

1 the depths of the excavations, but they would increase the volume of a potential release of 

2 process solutions and other liquid byproduct wastes if a catastrophic release were to occur.

3

4 Another important difference between Alternative 3 and the Proposed Action is that the north 

5 site is not underlain by shallow ground water and, thus, a CBW would not be required. As a 

6 result, the soils loss and soils compaction associated with construction of the CBW at the south 

7 site would not occur under Alternative 3. 

8

9 The potential impacts to geology and soils from construction of Alternative 3 would be SMALL 

10 and similar to the Proposed Action. In addition, the potential impacts to geology and soils from 

11 the operation and aquifer restoration of Alternative 3 would be the same as those of the 

12 Proposed Action and would be SMALL. 

13

14 Alternative 3 would also result in similar impacts to the geology and soils of the Ross Project 

15 area during the Proposed Action’s decommissioning, except for activities associated with the 

16 decommissioning of the surface impoundments. The larger surface impoundments would 

17 require larger areas of recontouring and revegetation during site restoration, which would result 

18 in a marginally greater potential for the soils loss and soils compaction. However, the impacts 

19 to the surficial geology and soils as a result of the Applicant’s cutting through the CBW to re20 establish aquifer flow in the Proposed Action would be eliminated. In total, the potential impacts 

21 to geology and soils during the decommissioning of Alternative 3 would be SMALL.

22

23 4.5 Water Resources

24

25 The Proposed Action could impact water resources, both surface and ground waters, during all 

26 phases of the Project’s lifecycle. As discussed in Section 3.2.4, surface and ground waters in 

27 the Ross Project area are currently used for livestock and wildlife watering, crop irrigation, and 

28 enhanced oil recovery (EOR). The largest water right within 3 km [2 mi] of the Ross Project 

29 area is Permit No. P6046R for the Oshoto Reservoir with a permitted capacity of 21 ha-m/yr 

30 [173 ac-ft/yr]. The Applicant proposes to convert this water right for use at the Ross Project 

31 (Strata, 2011a). The Applicant would have the option of providing alternative sources of water 

32 to supply the EOR operation. This section describes the potential impacts to water resources 

33 and the corresponding mitigation measures the Applicant proposes throughout the Proposed 

34 Action’s lifecycle as well as those of the two other Alternatives. 

35

36 4.5.1 Alternative 1: Proposed Action

37

38 Alternative 1 consists of four phases: construction, operation, aquifer restoration, and 

39 decommissioning of an ISR uranium-recovery facility and wellfields.

40

41 The Ross Project has the potential to impact quantity and quality of surface and ground waters 

42 to varying degrees during each phase of the project. The Applicant intends to use local water 

43 for the construction of the facility and wellfields, operation of the Proposed Action, and its 

44 aquifer restoration, and decommissioning phases. Consumptive ground-water use results from 

45 the Applicant injecting 1.25 percent less water than is withdrawn during uranium-recovery 

46 operation. Non-production surface- and ground-water use for domestic needs, dust control, and 

47 agricultural irrigation is provided in the Table 4.3.
DRAFT Environmental Impacts and Mitigation Measures

4-25

Table 4.3

Estimated Non-Production Water Use

Type of Use Source

Typical Water Usage 

(L/min [gal/min])

Construction Operation Restoration Decommissioning

Domestic Ground Water 3.4 [0.9] 7.2 [1.9] 6.1 [1.6] 6.8 [1.8]

Dust Control Surface Water 27.2 [7.2] 13.6 [3.6] 13.6 [3.6] 27.2 [7.2]

Irrigation Ground Water 0.4 [0.1] 0.4 [0.1] 0.4 [0.1] 0.4 [0.1]

Construction Surface Water 60.2 [15.9] 31.4 [8.3] 0.0 31.4 [8.3]

TOTAL 91.2 [24.1] 52.6 [13.9] 20.1 [5.3] 48.8 [12.9]

1 Source: Modified From Strata, 2012a.

2

3 The Applicant anticipates that ground water from the shallow-monitoring (SM) zone would be 

4 used for domestic purposes and agricultural irrigation, while surface water from either the 

5 Oshoto Reservoir or the Little Missouri River would be used for road and construction dust 

6 control. Although the GEIS Section 4.4.4.1 did not address consumptive use of surface water, 

7 and it assumed that all required water uses would be provided by ground water, the analysis of 

8 impacts to ground water and surface water is nonetheless applicable due to the fact that 

9 process water from ground water is the largest component of Ross Project water use. 

10

11 In addition, the Applicant proposes BMPs consistent with those identified by NRC as commonly 

12 employed at ISR facilities and that are summarized in GEIS Section 7.4 (Strata, 2011a; NRC, 

13 2009b).

14 4.5.1.1 Ross Project Construction

15

16 Surface Water 

17

18 As described in GEIS Sections 4.2.4.1.1 and 4.4.4.1.1, the potential impacts to surface waters 

19 that could result from the construction of the Proposed Action include land clearance and 

20 disturbance for buildings and auxiliary structures as well as the surface impoundments, 

21 wellfields, pipelines, access roads, and utilities; stream-channel disturbance for limited periods 

22 and minor wetland encroachment. In addition, spills and leaks of fuels and lubricants as well as 

23 the discharge of well-drilling fluids from installation, development, and testing of wells could 

24 potentially impact surface-water quality. The potential for these impacts would be mitigated 

25 through proper planning, thoughtful design, sound construction methods, permit requirements, 

26 and BMPs as described in GEIS Section 7.4 (NRC, 2009). The GEIS considered that changes 

27 to stream flow (from land grading and other topographic changes) and to natural drainage 

28 patterns would be mitigated or restored after the ISR facility’s construction phase is complete. 

29 Additionally, while impacts from incidental spills into surface water drainages could occur, they 

30 would be expected to be only temporary. The quality of storm water discharged during the 

31 construction phase would be controlled by permits from cognizant regulatory authorities. The 

32 GEIS concluded that potential impacts to surface water during the construction phase of an ISR 

33 facility would be expected to be SMALL to MODERATE, depending upon site-specific 

34 conditions.
DRAFT Environmental Impacts and Mitigation Measures

4-26

1 The Applicant intends to use approximately 88 L/min [23 gal/min] of surface water from either 

2 the Oshoto Reservoir or the Little Missouri River for dust control during construction (see Table 

3 4.3). This equates to an annual use of 4.6 ha-m [37 ac-ft/yr], significantly less than the currently 

4 permitted annual appropriation for Oshoto Reservoir of 21 ha-m [173 ac-ft/yr]. Thus, the 

5 potential impacts of the Proposed Action’s construction to surface-water quantity would be 

6 SMALL.

7

8 Suspended-sediment concentrations in storm water at the Ross Project area could be increased 

9 due to vegetation removal and soil disturbance during construction of the Proposed Action. The 

10 Applicant estimates that 45 ha [110 ac], or 7 percent of the Ross Project area, would be 

11 disturbed by the end of the construction phase (Strata, 2011a). Given this disturbance, the 

12 Applicant would need to obtain a “Large Construction General WYPDES Storm Water Permit” 

13 from WDEQ/WQD for the Proposed Action. Under this Permit, the Applicant would be required 

14 to implement a SWPPP to address storm-water runoff during construction activities. The 

15 SWPPP would describe the nature and sequence of construction activities, identify potential 

16 sources of pollution, and describe the BMPs that must be used, including erosion and sediment 

17 controls (e.g., silt fences, sediment logs, and/or straw-bale check dams) and operational 

18 controls (e.g., housekeeping, signage, and/or hydrocarbon storage requirements).

19

20 In addition, the construction of a single well (injection, projection, or monitoring) would generate 

a quantity of drilling fluid estimated at 22,700 L [6,000 gal] and about 11 m3 [15 yd3 21 ] of drilling 

22 muds. In total 1,500 – 2,000 wells would be drilled and the wastes generated could potentially 

23 impact water quality. However, the wells would be drilled at different times throughout the 

24 Project. The drilling fluids and muds would be contained in a mud pit constructed near the well 

25 that is being installed to prevent discharge to surface water. These wastes would then be 

26 evaporated and dried over time.

27 Other potential surface-water impacts could occur from leaking fuel or lubricants from heavy 

28 construction equipment and passenger vehicles that would be operated during the construction 

29 phase of the Proposed Action. Any such leaks of equipment fluids would be mitigated by the 

30 Applicant locating construction activities away from surface-water features, when possible, and 

31 rapidly responding to leaks by properly sealing the equipment as needed and by containing and 

32 cleaning up the leakage.

33

34 Stream channels within the Ross Project would be potentially impacted when crossed by roads, 

35 pipelines, and utilities. The Applicant estimates that three stream-channel crossings would be 

36 constructed and one existing stream-channel crossing would need to be rehabilitated during the 

37 construction phase of the Proposed Action. In addition, there are several instances where 

38 tertiary roads would access wellfields and would cross ephemeral drainages. To mitigate 

39 impacts, these channel crossings would consist of unconstructed, two-track roads that would be 

40 constructed away from drainages where possible; ephemeral channel crossings would involve 

41 minimal land disturbance, and they would not be used during flow events. In the instances 

42 where it is necessary to cross a stream channel, the crossing would be made perpendicular to 

43 the channel and would include a culvert capable of passing the runoff resulting from a 10-year, 

44 24-hour precipitation event. Sediment load would be mitigated by sediment-control BMPs. 

45 Pipeline crossings would be constructed in the same corridor as road crossings where possible 

46 to minimize disturbance. The impacts to surface-water flow from construction activities across a 

47 stream channel would also be minimized by the Applicant routing flow around active 

48 construction activities, storing the water in temporary sediment surface impoundments, or 
DRAFT Environmental Impacts and Mitigation Measures

4-27

1 passing the water through sediment-control measures prior to discharge (Strata, 2011a). Given 

2 the site-specific mitigation measures to be implemented by the Applicant, the potential impacts 

3 of the Proposed Action’s construction to surface-water quality would be SMALL.

4

5 The Applicant has applied for a permit with the U.S. Army Corps of Engineers (USACE) through 

6 USACE’s Section 404 of the Clean Water Act (CWA) permitting process that, if granted, would 

7 authorize dredge and fill activities and require the Applicant to mitigate the disturbance of 

8 wetlands. While the impacts to surface water could have MODERATE impacts before mitigation 

9 (NRC, 2009), the Section 404 permit would establish conditions that could mitigate such 

10 impacts. The Applicant anticipates that it would be required to operate in accordance with a 

11 Nationwide Permit (NWP) for specific construction activities.

12

13 The Ross Project area hosts approximately 26 ha [65 ac] of potential wetlands mostly situated 

14 along the Little Missouri River and adjacent to the Oshoto Reservoir (Strata, 2011a). 

15 Construction of the Proposed Action would have the potential to impact up to 0.8 ha [2 ac] of 

16 wetlands. Prior to disturbing any USACE-verified wetlands, the Applicant would apply for 

17 coverage under a USACE permit for specific construction activities such as pipeline installation 

18 and access-road stream-channel crossings. For example, the Permit application would require 

19 the Applicant to provide a site-specific mitigation plan for construction-related disturbance of

20 jurisdictional wetlands (i.e., wetlands regulated by the USACE under Section 404 of the CWA). 

21

22 Depending upon the nature of the anticipated wetlands disturbance, mitigation could include the 

23 Applicant re-establishing temporarily disturbed wetlands in place, enhancing other existing 

24 wetlands, or constructing additional wetland areas for circumstances where the disturbance 

25 would be long term. Mitigation measures would ensure that the Proposed Action does not result 

26 in a net loss of wetlands. Thus, while the impacts to wetlands could have MODERATE impacts 

27 before mitigation (NRC, 2009), a USACE CWA permit would establish conditions that could 

28 mitigate such impacts to wetlands. The potential impacts of the Proposed Action’s construction 

29 to wetlands consequently would be SMALL.

30

31 Ground Water

32

33 As stated in GEIS Section 4.2.4 and 4.4.4, potential impacts to ground water during an ISR 

34 facility’s construction are primarily from consumptive water use and contamination caused by:

35 drilling fluids and muds during injection, recovery, and monitoring well drilling; and fuel and 

36 lubricant spills and leaks from construction equipment. It is further noted in the GEIS that 

37 ground-water use during an ISR facility’s construction phase would be limited, and that ground 

38 water would be protected by implementing BMPs such as spill-prevention and spill-cleanup 

39 protocols. A limited amount of drilling fluids and muds would be introduced into the environment 

40 during well installation. Because of the limited nature of construction activities and the 

41 implementation of BMPs to protect shallow ground water, the GEIS concluded that construction 

42 impacts on ground water would be SMALL (NRC, 2009).

43

44 Although construction of the CBW during the Proposed Action is not part of the typical ISR 

45 design considered in the GEIS, the analysis of impacts to ground water provided in the GEIS 

46 are applicable because the effects of the CBW on shallow ground water are localized and the 

47 presence of the CBW would not affect the surrounding ground water.
DRAFT Environmental Impacts and Mitigation Measures

4-28

1 In the following sections, potential impacts and mitigation measures are considered for three 

2 aquifer units: 1) The unconfined shallow (near-surface) aquifers; 2) the confined aquifers 

3 hosting the ore-zone (OZ) as well as those above and below the ore zone (the shallow4 monitoring [SM] and the deep-monitoring [DM]); and 3) the deeper aquifers below the DM 

5 aquifer. 

6

7 Shallow Aquifers

8

9 Potential impacts to the quantity of water in the shallow aquifers during construction of the 

10 Proposed Action would be caused by the quantity taken from the Oshoto Reservoir and the 

11 quantity involved in the installation of the CBW surrounding the facility (i.e., the CPP and 

12 surface impoundments). In the vicinity of the Oshoto Reservoir, the Reservoir stage (i.e., the 

13 volume of water it contains) and the shallow-aquifers water levels are closely related (Strata, 

14 2012b). Although the Applicant anticipates an annual withdrawal of 4.6 ha-m/yr [37 ac-ft/yr] of 

15 water during construction, that volume is less than the permitted annual appropriation for the 

16 Oshoto Reservoir, 21 ha-m/yr [173 ac-ft/yr] (Strata, 2012b). Any changes in ground-water 

17 levels due to water usage from Oshoto Reservoir would be small and restricted to the area 

18 around the Reservoir.

19

20 Construction of the CBW (see SEIS Section 2.1.1.1) could impact the quantity of water in the 

21 shallow aquifer because the CBW would isolate the shallow aquifer at the Ross Project facility. 

22 Preconstruction dewatering within the facility’s area would lower water levels locally in the 

23 shallow aquifer, but the normal ground-water flow regime would not be disrupted. The Applicant

24 anticipates that the construction dewatering following installation of the CBW would be a one25 time event and require little continuing maintenance. Ground-water use would be mitigated by 

26 the design of the CBW, which would prevent any leakage inside the CBW that would require 

27 removal by pumping. Thus, the potential impacts from the construction of the Proposed Action 

28 to ground-water quantity in the shallow aquifers would be SMALL.

29 In addition, shallow-aquifer water levels could increase slightly on the hydraulically up-gradient 

30 side of the CBW and could decrease slightly on the hydraulically down-gradient side of the CBW 

31 in response to the lower permeability of the CBW relative to the shallow aquifer. The changes 

32 in ground-water levels would be restricted to the area adjacent to the CBW (Strata, 2011a).

33

34 Potential water-quality impacts to the shallow aquifer that could occur during construction 

35 include spills or leaks from construction equipment and the introduction of drilling fluids. The 

36 potential for the shallow ground water to be impacted by drilling fluids and muds is minimal 

37 because of the small volume of fluids used, and because the fluids would be contained within a 

38 mud pit in accordance with WDEQ/LQD and EPA requirements. Impacts to ground water during 

39 well drilling would be further limited by the nature of the bentonite or polymer-based drilling 

40 additives in the drilling fluids. These additives are designed to limit infiltration in an aquifer (i.e., 

41 to a few inches) and to isolate the drillhole from the surrounding geologic materials via a wall42 cake or veneer of drilling-fluid filtrate, further diminishing the potential for impacts. Thus, the 

43 potential impacts of the Proposed Action’s construction to ground-water quality in the shallow 

44 aquifers would be SMALL.

45

46 Ore-Zone and Surrounding Aquifers

47

48 Ground water used for domestic uses and agricultural irrigation during the Proposed Action’s 

49 construction is estimated to be 3.8 L/min [1.0 gal/min] (see Table 4.3). A water-supply well 
DRAFT Environmental Impacts and Mitigation Measures

4-29

1 drawing water from the SM aquifer would be used to supply these needs. Based upon yields 

2 from regional baseline wells and other wells completed in the SM aquifer, ground-water 

3 modeling indicates that the aquifer could support this level of withdrawal with little drawdown 

4 (Strata, 2011b). The potential impacts of the Proposed Action’s construction on the ground5 water quantity available from the confined aquifers, therefore, would be SMALL.

6

7 Drilling for mineral delineation and well installation would potentially impact the SM aquifer, the 

8 OZ aquifer laterally adjacent to the ore zone, and the DM aquifer. Improperly abandoned 

9 drillholes, overly penetrating drillholes, or lack of well integrity could result in the mixing of 

10 industrial-use ground water from the OZ aquifer with the chloride-dominated ground water of the 

11 DM aquifer or the stock-water quality of the overlying SM aquifer. This mixing would be 

12 localized and any significant changes in water quality would be detected by monitoring wells.

13

14 To mitigate potential impacts to the confined aquifers from drilling, the Applicant proposes to 

15 continue to comply with WDEQ/LQD rules for well completion and drillhole abandonment 

16 (WDEQ/LQD, 2005). The Applicant would rely upon the geological model developed to 

17 determine total depths for drill holes, thus preventing over-penetration into underlying aquifers. 

18 Onsite geological and engineering supervision would continue throughout the construction 

19 phase. Wells installed for further hydrologic studies, pre-licensing baseline site characterization, 

20 and production infrastructure would pass mechanical integrity testing (MIT) prior to use (see 

21 SEIS Section 2.1.1). Consequently, the potential impacts from the Proposed Action’s 

22 construction on the ground-water quality within the confined aquifers would be SMALL.

23

24 Deep Aquifers

25

26 Construction of the Ross Project would not impact the aquifers below the DM aquifer. The 

27 Flathead and Deadwood Formations would be tapped by the construction of the Class I injection 

28 well(s) discussed in SEIS Section 2.1.1, where that well(s) would be used for the disposal of 

29 brine and other byproduct liquid wastes during the Ross Project’s operation, aquifer restoration, 

30 and decommissioning phases. The potential impacts of construction of the Proposed Action on 

31 the quantity and quality of ground water present within the deep aquifers would be SMALL.

32

33 4.5.1.2 Ross Project Operation

34

35 This section describes potential impacts and mitigation measures to surface and ground waters 

36 associated with operation of the Proposed Action. 

37

38 Surface Water and Wetlands

39

40 As described in GEIS Sections 4.2.4 and 4.4.4, surface waters could be impacted by accidental 

41 spills during ISR operations. Spills from the CPP or wellfields as well as spills during 

42 transportation could impact storm-water runoff or contaminate shallow aquifers that are 

43 hydraulically connected to surface waters. The GEIS determined that surface-water monitoring 

44 and spill response would limit the impacts of potential surface spills to SMALL; however, 

45 impacts of spills to surface waters that are connected to shallow aquifers would be SMALL to 

46 MODERATE, depending upon the specifics of an incident. Activities posing potential impacts to 

47 surface waters from uranium-recovery operation would be regulated by Federal agencies. 

48 According to the GEIS, the Applicant’s use of BMPs, and implementation of required mitigation 
DRAFT Environmental Impacts and Mitigation Measures

4-30

1 measures would moderate the impacts of the Proposed Action’s operation from MODERATE to 

2 SMALL, depending upon local conditions.

3

4 The Applicant estimates that approximately 45 L/min [12 gal/min] of surface water from either 

5 the Oshoto Reservoir or the Little Missouri River would be used during the Proposed Action’s 

6 operation for continuing construction activities in the wellfields and for dust control (see Table 

7 4.3). The estimated annual use of 2.4 ha-m [19 ac-ft/yr] would be significantly less than the 

8 existing, permitted annual appropriation for Oshoto Reservoir of 21 ha-m [173 ac-ft/yr]. Ground 

9 water produced from monitoring and testing wells outside the exempt (ore-zone or OZ) aquifer 

10 would be discharged according to a temporary WYPDES Permit, comparable to the permit 

11 obtained by the Applicant for development of its monitoring wells installed in 2010. This water 

12 would either infiltrate into the ground or add to the surface water in the Little Missouri River.

13

14 Flow in the Little Missouri River could potentially be affected during operation. Water from the 

15 Little Missouri River infiltrates into the OZ aquifer where the Fox Hills and Lance Formations 

16 outcrop at the ground surface east of the Ross Project area (Strata, 2011a). The Applicant’s 

17 ground-water model shows that infiltration would increase by approximately 6 L/min [1.5 

18 gal/min], decreasing the average annual discharge of the Little Missouri River by less than 

19 0.005 percent just downstream of the Wyoming-Montana border (Strata, 2011a). Thus, no 

20 mitigation measures would be warranted for this very small volume and the potential impacts of 

21 the Proposed Action’s operation on surface-water quantity would be SMALL. 

22

23 Storm-water runoff from impervious surfaces, including buildings, roads, and parking areas, 

24 could result in higher water flows, channel erosion, and increased sediment concentrations in 

surface waters. The Applicant predicts a peak flow of 1.4 m3

/s [50 ft3 25 /s] during a 100-year, 24-

26 hour storm (Strata, 2011a). This peak flow represents an increase of less than 1 percent of the 

peak flow in the Little Missouri River of 170 m3

/s [6,000 ft3 27 /s]. In addition, BMPs would be 

28 implemented by the Applicant to reduce erosion and the likelihood of increased sediment loads. 

29 Surface-water runoff would be mitigated by the Proposed Action’s storm-water control system 

30 that would route all storm water to a sediment surface impoundment sized to hold runoff from 

31 the 100-year, 24-hour runoff event. A flood-control diversion channel around the CPP and 

32 surface impoundments (i.e., the facility itself) would prevent storm water originating in the 

33 ephemeral stream channel upstream of the facility from encountering process solutions or 

34 chemicals. Mitigation measures employed by the Applicant to reduce soil erosion would also 

35 mitigate storm-water runoff across the Ross Project. Protection of wellheads and module 

36 buildings from large runoff events would typically be accomplished by placement on high ground 

37 out of the flood plain. When wells or other facility components must be placed within the 100-

38 year-flood inundation area, appropriate engineering controls would be used to ensure safety 

39 and environmental protection. The injection, recovery, and monitoring wells would be protected 

40 from flooding by the installation of cement seals around the well casings and the use of 

41 watertight well caps. 

42

43 Measures designed to mitigate the impacts from suspended sediment would be contained in the 

44 WYPDES Storm-Water Permit required by the Applicant prior to uranium-recovery operation. 

45 The Permit would include a SWPPP that describes erosion and sediment controls as well as 

46 operational controls that would be used to ensure that storm-water discharges from the Ross 

47 Project facility do not cause a violation of Wyoming’s surface-water quality standards 

48 (WDEQ/WQD, 2007). Storm-water BMPs would be inspected semiannually or as required by 
DRAFT Environmental Impacts and Mitigation Measures

4-31

1 the WYPDES Storm-Water Permit. The SWPPP would be updated as needed, such as when 

2 potential problems are identified during inspections or when there are changes in uranium3 recovery operation (e.g., transition from operation to aquifer restoration). The WYPDES Storm4 Water Permit would also require storm-water discharge sampling and analysis as well as 

5 compliance with a numeric effluent limit for total suspended sediment. 

6

7 Release of process solutions from uranium-recovery wellheads, pipelines, module buildings, or 

8 process vessels; accidental discharge from surface impoundments; or release of yellowcake or 

9 IX resin during a transportation accident could result in surface-water contamination if the 

10 release(s) reached a surface-water body. Impacts from releases that do reach surface water(s) 

11 would be short-term, elevated concentrations of radionuclides and associated chemical 

12 constituents at levels above post-licensing, pre-operational baseline conditions. Cleanup of 

13 contaminated sediments associated with a spill would follow the same requirements as those for 

14 soil cleanup efforts (see SEIS Section 4.4.1.2). Any impacts to surface waters would decline 

15 over time as the contaminated fluids are dispersed in the surface-water body. 

16

17 The potential for release of process solutions would be mitigated by the control system in place 

18 at the Ross Project which continually monitors pressure and flow. Accidental discharge from 

19 surface impoundments would be mitigated by the size and design of the impoundments and by 

20 regular inspections. Because roads would cross surface-water drainages in only a few, isolated 

21 locations, it is unlikely that a transportation accident would result in a release to any surface 

22 water. Further mitigation of impacts would be accomplished by Applicant’s personnel containing 

23 and cleaning up any release before the solution could migrate to a surface-water body. 

24 Therefore, given these mitigation measures, the potential impacts of the operation of the 

25 Proposed Action on surface-water quality would be SMALL.

26

27 The potential impacts of the Proposed Action’s operation to the Ross Project area’s wetlands 

28 would be the same as described for the Ross Project’s construction-phase impacts and the 

29 impacts would be SMALL.

30

31 Ground Water

32

33 The GEIS concluded in GEIS Sections 4.2.4 and 4.4.4 that the amounts of ground water used in 

34 routine activities such as dust suppression, cement mixing, and well drilling are small and would 

35 have a SMALL and temporary impact. 

36

37 At an ISR facility, a network of buried pipelines would be used during in situ uranium recovery 

38 for transporting lixiviant between pump houses and the CPP as well as connecting injection and 

39 extraction wells to manifolds inside the header houses. The failure of pipeline fittings or valves, 

40 or well mechanical-integrity failures, in shallow aquifers could result in spills or leaks of lixiviant, 

41 which could impact water quality in the shallow aquifers. Potential environmental impacts due 

42 to spills and leaks from pipelines could be MODERATE to LARGE depending upon site-specific 

43 conditions, including whether 1) the ground water in the shallow aquifers is close to the ground 

44 surface; 2) the shallow aquifers are important sources for local domestic or agricultural water 

45 supplies; or 3) the shallow aquifers are hydraulically connected to other locally or regionally 

46 important aquifers; or 4) the shallow aquifers have either poor water quality or yields that are not 

47 economically suitable for production (NRC, 2009). The use of surface impoundments to 

48 manage process solutions generated during ISR activities could also impact shallow aquifers by 

49 failure of impoundment embankments or their liners. Potential impacts of such failures would be 
DRAFT Environmental Impacts and Mitigation Measures

4-32

1 expected to be minimized as stated in the NRC license, where requirements such as installation 

2 of leak-detection systems, maintenance of reserve capacity, and embankment inspections 

3 would be required. Thus, the GEIS concluded that impacts of the use of surface impoundments 

4 on ground water would be SMALL (NRC, 2009).

5

6 As discussed in GEIS Sections 4.2.4 and 4.4.4, potential environmental impacts to ground7 water resources in the OZ and surrounding aquifers include consumptive water use and 

8 changes to water quality (NRC, 2009). Consumptive use arises from the fact that ISR 

9 operations withdraw about 2 percent more water than is injected into the wellfields, which is 

10 referred to as “production bleed.” Ground-water bleed ensures a net inflow of ground water into 

11 the wellfield to minimize the potential movement of lixiviant and its associated contaminants out 

12 of the wellfield. Bleed water is generally disposed of through a waste-water control system, and 

13 it is not re-injected into the ISR wellfields. The GEIS determined that the short-term impacts of 

14 consumptive use could be MODERATE, but temporary, if the OZ aquifer outside the exempted 

15 portion of ore zone is used locally. (Uranium-recovery requires exemption of the uranium16 bearing aquifer as an underground source of drinking water and is exempted through 

17 Wyoming’s UIC program administered by the WDEQ.). Therefore, the long-term consumptive18 use impacts would be expected to be SMALL in most cases, depending on site-specific 

19 conditions. 

20

21 The GEIS noted that water quality in the OZ aquifer would be degraded during ISR operations 

22 (NRC, 2009). A licensee would be required, by its WDEQ Permit to Mine and would be by its 

23 NRC license, to initiate aquifer-restoration activities to restore the OZ aquifer to preoperational 

24 conditions, if possible. If the aquifer cannot be returned to post-licensing, pre-operational 

25 conditions described in SEIS Section 2.1.1.1, the NRC would require that the aquifer meet the 

26 U.S. Environmental Protection Agency (EPA) maximum contaminant levels (MCLs) provided in 

27 10 CFR Part 40, Appendix A, Table 5C or Alternate Concentration Limits (ACLs), as approved 

28 by NRC (10 CFR Part 40; NRC, 2009b). For these reasons, the NRC determined in the GEIS 

29 that potential impacts to water quality of the uranium-bearing aquifer (i.e., ore zone, production 

30 zone or unit, or mineralized zone) as a result of ISR operations would be expected to be SMALL 

31 and temporary (NRC, 2009).

32

33 In GEIS Section 4.2.4 as cited by GEIS Section 4.4.4, the potential for vertical and horizontal 

34 excursions of degraded ground water outside of the uranium-production zone (i.e., the ore zone) 

35 is discussed. The impact of horizontal excursions could be MODERATE or LARGE, if a large 

36 volume of contaminated water leaves the ore zone and moves down-gradient and impacts an 

37 area outside the ore zone which is being used for consumption (NRC, 2009). The historical 

38 record for several licensed ISR facilities indicates that excursions occur at ISR operations (NRC, 

39 2009). Most of the excursions are horizontal and were recovered within months after detection. 

40 Vertical excursions tend to be more difficult to recover than horizontal excursions, and in a few 

41 cases, remained on excursion status for as long as eight years. The vertical excursions were 

42 traced to thinning of the confining geologic interval below the ore zone and improperly 

43 abandoned drillholes from earlier exploration activities (NRC, 2009).

44

45 To reduce the likelihood and consequences of potential excursions, the NRC requires licensees

46 to identify preventive measures before starting ISR operations. In general, the potential impacts 

47 of vertical excursions to ground-water quality in surrounding aquifers would be SMALL if the 

48 vertical hydraulic-head gradients between the OZ aquifer and the adjacent aquifer are small; if 

49 the vertical hydraulic conductivities of the confining geologic units are low; and if the confining 
DRAFT Environmental Impacts and Mitigation Measures

4-33

1 geologic units are sufficiently thick (NRC, 2009). Environmental impacts, however, would be 

2 expected to be MODERATE or LARGE if the confining units are discontinuous, thin, or fractured 

3 (NRC, 2009). The NRC requires assurance of the integrity of the confining units to minimize the 

4 potential impacts from horizontal excursions.

5

6 As indicated in GEIS Sections 4.2.4.2.2.3 and 4.4.4.2.2.3, the potential environmental impacts 

7 from disposal of liquid effluents into deep aquifers below ore-bearing aquifers would be SMALL, 

8 if water production from the deep aquifers is not economically feasible; if the ground-water 

9 quality from these aquifers is not suitable for domestic or agricultural uses (e.g., high salinity); 

10 and if they are confined above by sufficiently thick and continuous low-permeability layers 

11 (NRC, 2009). Under different environmental laws such as the CWA, the Safe Drinking Water 

12 Act, and the Clean Air Act (CAA), the EPA has statutory authority to regulate activities that could 

13 affect the environment. Underground injection of liquids requires a permit from the EPA or from 

14 an authorized State UIC program. As noted in SEIS Section 2.1, the WDEQ has been 

15 authorized to administer the UIC program in Wyoming.

16

17 In the following sections, the potential impacts and mitigation measures related to the Proposed 

18 Action’s operation are considered for the three types of aquifers: 1) the unconfined shallow (i.e., 

19 near-surface) aquifers; 2) the confined aquifers hosting the ore zone as well as those above and 

20 below the ore zone (the SM and the DM aquifers); and 3) the deep aquifers below the DM 

21 aquifer.

22

23 Shallow Aquifers

24

25 Potential impacts from operation to ground-water quantity in the shallow aquifers would be

26 similar to those described for the Proposed Action’s construction phase and would be SMALL.

27

28 During ISR operation, the water quality throughout the Ross Project has the potential to be 

29 impacted by accidental spills or leaks from chemical-storage areas, process-solution vessels, or 

30 the surface impoundments as well as by spills and leaks of lixiviant from failure of a pipeline or a 

31 shallow break in the casing of an injection or recovery well. To reduce the risk of pipeline 

32 failure, the Applicant would hydrostatically test all pipelines prior to use and install leak-detection 

33 devices in manholes along the pipelines. The Applicant’s implementation of BMPs during Ross 

34 Project operation would reduce the likelihood and magnitude of spills or leaks and facilitate

35 expeditious cleanup.

36

37 Further, the Applicant would monitor recovery and injection pipelines and immediately shut 

38 down affected pumps if a spill or leak were detected (Strata, 2011b). The CPP would include a 

39 control room where a master control-system would allow remote monitoring and control of ISR, 

40 wellfield, and deep-well-disposal operations (Strata, 2011b). Operators would be located in the 

41 CPP’s control room 24 hours a day and would use a computer-based station to command the 

42 control system.

43

44 MIT would be conducted on all Class III injection wells, recovery wells, and monitoring wells 

45 (see SEIS Section 2.1.1). Construction of all wells and their respective MIT would comply with 

46 the pertinent WDEQ/LQD regulations (WDEQ/LQD, 2005).

47

48 The Applicant would also implement spill control, containment, and cleanup measures in the 

49 CPP and surface-impoundment areas (i.e., the facility). These measures would include 
DRAFT Environmental Impacts and Mitigation Measures

4-34

1 secondary containment for process-solution vessels and chemical storage tanks, a geosynthetic 

2 liner beneath the CPP’s foundation, dual liners with a leak-detection system for the surface 

3 impoundments, and a sediment impoundment to capture storm-water runoff. In the event of a 

4 surface-impoundment leak, sufficient capacity would be reserved in the other impoundments’ 

5 cells to allow the contents of the leaking cell to be rapidly transferred, minimizing the volume of 

6 the release. In addition, the ground-water levels within the CBW would be maintained below the 

7 ground-water levels in the shallow aquifer outside the CBW. This would impose inward and 

8 upward hydraulic gradients and therefore minimize the potential for contaminated ground water 

9 to migrate into the regional system. Thus, the potential impacts of the Proposed Action’s 

10 operation to ground-water quality in the shallow aquifers would be SMALL.

11

12 Ore-Zone and Surrounding Aquifers 

13

14 Potential impacts from the consumptive use of ground water from the ore-zone and surrounding 

15 aquifers were evaluated by the Applicant using a regional numerical model (Strata, 2011b). The 

16 conditions simulated by the Applicant were for two ISR “mine units” operating simultaneously, 

17 as described in SEIS Section 2.1.1. Details of the ISR simulations and results of the modeling 

18 are provided in Addendum 2.7-H of the Applicant’s TR (Strata, 2011b). 

19

20 During the production simulation, each wellfield module was estimated to operate at a maximum 

21 rate of 44 L/s [700 gal/m] or 1.10 L/s [17.5 gal/m] per well. Estimated bleed rate during 

22 production was estimated at 1.25 percent (0.55 L/s [8.75 gal/m] per module, 0.0138 L/s [0.219 

23 gal/m] per recovery well). The ground-water sweep operation was estimated to remove 50 

24 percent of the pore volume of the wellfield (see SEIS Section 2.1.1.2). Based upon the three25 month sweep period, the estimated flow rate during sweep was 0.0827 L/s [1.31 gal/m] per 

26 recovery well. Aquifer-restoration activities were assumed to last approximately six months 

27 (actual time could vary based upon wellfield conditions). The bleed during restoration would be 

28 expected to vary depending upon whether or not aquifer restoration is occurring concurrent with 

29 uranium recovery in other wellfields. When restoration is occurring in one wellfield and uranium 

30 recovery is simultaneously occurring in another wellfield, excess bleed from the well undergoing 

31 uranium recovery would be used to offset reverse-osmosis (RO) losses within the wellfield in 

32 restoration. 

33

34 The simulations assumed no changes in flow rates within the stock and domestic wells within 

35 the model area. Estimated flow rates for the oil-field water-supply wells were developed based 

36 upon average historical flow rates for the last two years of recorded flow (2008 and 2009). 

37 Three of the oil-field water-supply wells (Nos. 22X-19, 19XX, and 789V) are located immediately 

38 adjacent to Modules 2-6 and 2-7. The Applicant has been in communication with Merit, the 

39 owner of these wells, and is currently exploring alternative water sources that would allow it to 

40 suspend use of the wells before and during uranium recovery. Currently, the goal is to have the 

41 Merit wells shut off approximately two years prior to uranium recovery. Given the uncertainty 

42 associated with the future status of the Merit wells, the Applicant simulated two uranium43 recovery scenarios. Scenario 1 assumed that an alternative water supply could be found, 

44 allowing the Merit wells to be taken out of operation two years prior to uranium recovery, and 

45 kept out of operation until recovery operations cease. Scenario 2 assumed that an alternative 

46 water supply source could not be located and that, during uranium-recovery operation, the Merit 

47 oil-field water-supply wells operated at the assumed 2008 – 2009 average flow rates.
DRAFT Environmental Impacts and Mitigation Measures

4-35

1 The maximum modeled drawdowns for select wells in the OZ aquifer, within and adjacent to the 

2 Ross Project area, at the end of uranium-recovery operation and aquifer restoration for the two 

3 scenarios are presented in Addendum 2.7-H of the Applicant’s TR (Strata, 2011b). The most 

4 significant estimated drawdown occurs in the Wesley No. TW02 well located in the SWSW 

5 Section 8, Township 53 North, Range 67 West, with 10.2 m [33.3 ft] of drawdown or 42.4 

6 percent of the available head under Scenario 2 at the end of aquifer restoration. This well 

7 supplies water to a structure that is currently used by the Applicant as its Field Office for the 

8 Ross Project and to provide water to livestock. 

9

10 Potential impacts to the SM-aquifer water quantity, because of withdrawals during uranium 

11 recovery and aquifer restoration in the ore zone, were also evaluated by the regional ground12 water model (Strata, 2011b). Under the two recovery scenarios evaluated, the estimated 

13 maximum amounts of drawdown ranged from 1.5 – 5 m [5 – 15 ft] within the Ross Project area 

14 following the Proposed Action’s operation and aquifer-restoration phases. 

15

16 Impacts from consumptive use of ground water from the ore zone would be minimized by 

17 cessation of water withdrawals by the Merit oil-field water-supply wells. The ground-water 

18 model simulated a single operational sequence of wellfield development, recovery, and aquifer 

19 restoration. Different operational approaches could be more effective in reducing impacts, and 

20 the Applicant proposes to investigate these as wellfield installation and testing progresses. 

21

22 In the event that uranium recovery at the Proposed Action prevents the full use of a well which 

23 provides water under a valid water right, the Applicant would commit to providing an alternative 

24 source of water of equal or better quality and quantity, subject to Wyoming water statute 

25 requirements.

26

27 In the regional numerical model, the model’s lower boundary was the base of the ore zone/top 

28 of the lower confining unit. As a result, potential impacts to the DM aquifer were not evaluated 

29 by the model. The DM aquifer supports only one well (Merit Well No. 22X-19), and it has only 

30 limited hydraulic conductivity and yield. Thus, as the model demonstrates, the potential impacts 

31 from the Proposed Action’s operation to ground-water quantity in the confined aquifers would be 

32 SMALL.

33

34 There is potential for water-quality impacts (vertical excursions) to the SM and DM aquifers from 

35 the lixiviant-fortified ground water during injection and withdrawal from the OZ aquifer, although 

36 this potential is mitigated by the natural confining units of fine-grained mudstones, siltstones, 

37 and claystones above and below the OZ aquifer (see SEIS Section 3.5). 

38

39 The Applicant tested the integrity of the lower confining unit separating the OZ aquifer from the 

40 DM aquifer with a six pump tests; in two of the six tests, pumping of the OZ aquifer showed a 

41 possible response in the DM aquifer (Strata, 2011a). These responses were interpreted by the 

42 Applicant as due to improperly plugged previous exploration drillholes that have not yet been 

43 properly abandoned. Other aquifer tests by Nubeth and the Applicant recorded no response in 

44 the aquifers vertically adjacent to the ore zone. Different water qualities, observed in the OZ 

45 and DM aquifers also support the premise of hydraulic separation. Stratigraphic sections 

46 created by the Applicant from the geologic logs of the drillholes have provided further support 

47 for the continuity and integrity of the shale confining units (Strata, 2011b). The thickness of the 

48 shale unit between the OZ and the DM aquifers is generally greater than 6 m [20 ft], except for 

49 an area along the southern edge of the Ross Project area where the unit thins to about 1.5 m [5 
DRAFT Environmental Impacts and Mitigation Measures

4-36

1 ft]. The Applicant would continue geologic evaluation and hydrologic testing to characterize the 

2 integrity of the lower confining unit, through observations of piezometric levels in the SM and 

3 DM aquifers.

4

5 The Applicant would implement a WDEQ-approved MIT program for all injection and recovery 

6 wells to ensure casing integrity (WDEQ/LQD, 2005). Breaches to the integrity of the confining 

7 unit from old exploration drillholes would be minimized by the Applicant locating the drillholes 

8 within the wellfields and beneath the Proposed Action as well as plugging and abandoning them 

9 with low-hydraulic-conductivity materials such as cement or heavily mixed bentonite grout 

10 according to methods approved by WDEQ as described in Section 2 of this SEIS (Strata, 

11 2011b). As of October 2010, the Applicant had located 759 of the 1,682 holes from Nubeth 

12 exploration activities and had plugged 55 of them (Strata, 2011b). The Applicant proposes to 

13 actively locate and plug all exploration drillholes prior to beginning wellfield operation. 

14

15 If the Ross Project were to be licensed by the NRC, the NRC license would include a 

16 requirement that the Applicant install a ring of monitoring wells around each wellfield. The wells 

17 would allow monitoring of the SM and DM aquifers as well as the OZ aquifer around their 

18 perimeters. The ground-water model discussed in SEIS Section 3.5.3, Local Ground-Water 

19 Resources, indicates that a spacing of 122 –183 m [400 – 600 ft] between the production 

20 wellfields and perimeter monitoring-well ring would be sufficient to detect an excursion; thus, 

21 spacing between the monitoring wells is also proposed to be 122 –183 m [400 – 600 ft] (Strata, 

22 2011b). The simulations indicated that a head change or hydraulic anomaly would rapidly 

23 become apparent in the perimeter wells before any geochemical changes in the ground water 

24 would be detected. The NRC would require an early-warning system of pressure transducers to 

25 detect anomalous hydrostatic pressure increases in the perimeter monitoring wells and 

26 sampling of monitoring wells with a semi-monthly frequency. Mitigation in the event of a vertical 

27 excursion of lixiviant-containing ground water to the SM or DM aquifers could require withdrawal 

28 and treatment of contaminated ground water from these aquifers. 

29 During the Proposed Action’s operation, the ground-water quality in the OZ aquifer would be 

30 impacted during uranium-recovery operation. The Applicant proposes to file an exemption 

31 request with WDEQ/LQD for exemption of the OZ aquifer as a source of drinking water based 

32 upon the fact that some constituents in the ground water (e.g., TDS, sulfate, ammonia, radium33 226+228, and gross alpha) currently exceed applicable standards for human or livestock water 

34 consumption as shown in Tables 3.6, 3.7, and 3.8 and in SEIS Section 3.5.3 (Strata, 2011b). 

35 The uranium and vanadium in the ore zone would be oxidized and mobilized by the introduction 

36 of lixiviant into the OZ aquifer through injection wells. In addition to the uranium and vanadium, 

37 other constituents would also be mobilized, including anions, cations, and trace metals (Strata, 

38 2011b). These impacts to the water quality of OZ aquifer within the wellfields would be short39 term because aquifer restoration would be required by the NRC license to return these 

40 constituent concentrations to each wellfield’s respective NRC-approved baseline (i.e., post41 licensing, pre-operational) concentrations, or ACLs as approved by the NRC.

42

43 The quality of the non-exempted OZ aquifer outside the perimeter monitoring-well rings could be 

44 impacted via a lateral excursion resulting from a local wellfield imbalance. A wellfield imbalance 

45 occurs when the rate of injected lixiviant exceeds the rate of extraction by the recovery wells, 

46 resulting in a migration of lixiviant laterally away from the wellfield. The Applicant proposes a 

47 computer-based control system, staffed 24 hours a day within the CPP, to monitor injection 
DRAFT Environmental Impacts and Mitigation Measures

4-37

1 pressures and recovery-well flow rates so that wellfield balance would be maintained (Strata, 

2 2011a). 

3

4 In the event of an operational upset, the ground-water model, integrated with injection and 

5 recovery well data, would allow for a determination of potential migration paths and assist the 

6 system’s operator in making decisions on mitigating actions. The Applicant notes that the 

7 heterogeneous lithology of the sandstones produces lateral and vertical variations in 

8 permeability, with uranium mineralization concentrated in the higher-permeability sediments. 

9 Lateral migration of lixiviant would therefore be limited by the less-permeable and un10 mineralized zones within the ore-zone sandstones.

11

12 Temporary impacts to water quality would result if an excursion were to occur. Typical lixiviant 

13 circulating through the ore zone would contain high concentrations of sodium, bicarbonate, 

14 chloride, and sulfate with TDS up to 12,000 mg/L and concentrations of uranium, vanadium, and 

15 radium greater than 100 mg/L (NRC, 2009; Strata, 2011a; WDEQ/WQD, 2011). As described in 

16 SEIS Section 3.5, the water qualities in the surrounding aquifers have much lower TDS, 

17 averaging 1,092 mg/L, 1,600 mg/L, and 1,268 mg/L in the SM, OZ, and DM aquifers, 

18 respectively, or about 10 percent of the TDS of the lixiviant. Preconstruction monitoring by the 

19 Applicant has shown concentrations of uranium (less than 0.004 mg/L]) and radium (less than 

20 0.01 Bq/L [0.4 pCi/L]) in the SM and DM aquifers (Strata, 2011a). Higher concentrations of 

21 uranium (maximum value of 0.109 mg/L) and radium (maximum value of 0.44 Bq/L [12.01 

22 pCi/L]) were measured in the ore zone (Strata, 2011a). Temporary impacts to water quality 

23 from an excursion of increased concentrations of TDS, uranium, radium, and other 

24 radionuclides as well as elements such as arsenic, selenium, and vanadium that are mobilized 

25 with the uranium would be expected.

26

27 The potential impacts of the operation of the Proposed Action to ground-water quality in the 

28 confined aquifers above and below the ore zone would, therefore, be SMALL. The short-term 

29 potential impacts of lixiviant excursions from uranium-recovery operation to the OZ aquifer 

30 outside the exempted area would be SMALL to MODERATE. Detection of excursions through 

31 the network of monitoring wells, followed by the Applicant’s pumping of ground water to recover 

32 the excursion would reduce long-term potential impacts to the OZ aquifer outside the exempted 

33 portion to SMALL.

34

35 Deep Aquifers

36

37 The Applicant plans to dispose of brine and other liquid byproduct wastes into five deep wells 

38 discharging into the Flathead and Deadwood Formations, which are defined as the Formations 

39 that occur beneath the base of the Icebox Shale member of the Winnipeg Group and above the 

40 top of the Precambrian basement. There are no porous and permeable zones below the 

41 Deadwood and Flathead Formations that would make suitable injection zones. Because of the 

42 depth in the stratigraphic column at which these Formations occur and the apparent lack of oil 

43 or other hydrocarbons, there has been little exploration of these intervals and few data are 

44 available for the Ross Project area. To improve its understanding of the targeted Formations, 

45 the Applicant plans to drill one deep well for hydraulic testing as a preconstruction activity 

46 (Strata, 2011a). If the capacity in the targeted Formation for injected solutions is less than 

47 anticipated by the Applicant, more wells than five may be needed.
DRAFT Environmental Impacts and Mitigation Measures

4-38

1 The UIC Class I Permit issued by the WDEQ identified the confining unit immediately above the 

2 discharge zone as consisting of approximately 16 m [52 ft] of Icebox Shale. An additional 

3 confining unit immediately above the Icebox Shale is the Red River Formation, which consists of 

4 97 – 140 m [318 – 460 ft] of cryptocrystalline to microcrystalline impermeable dolomite. The top 

5 of the discharge zone occurs about 2,488 m [8,163 ft] below the ground surface, and the total 

6 thickness of the injection zone for the wells is estimated to be 180 m [592 ft]. In issuing the UIC 

7 Permit, the WDEQ/WQD determined that, at the depths and locations of the injection zones 

8 specified in the Permit, the use of ground water from the Flathead and Deadwood Formations is 

9 economically and technologically impractical (WDEQ/WQD, 2011). 

10

11 The data that are available for the Formations targeted for deep-well injection suggest that 

12 ground water contains greater than 10,000 mg/L TDS. The estimated water quality of the brine, 

13 one liquid effluent that would be injected in the deep-injection wells, comprises the following 

14 constituent concentrations: 4,000 – 40,000 mg/L TDS; 5 – 25 mg/L uranium as U3O8; and 14.8 

15 – 92.5 Bq/L [400 – 2,500 pCi/L] Ra-226. Its pH is between 6 and 9. WDEQ concluded that the 

16 liquid effluents could be suitably isolated in the deep aquifers, and they would not affect any 

17 overlying underground sources of drinking water. The deep-injection wells would be installed 

18 and tested in accordance with WDEQ/WQD Class I disposal-well standards and the UIC Permit. 

19 The Permit requires the Applicant to control effluent pressures at the wellhead to ensure that the 

20 fracture pressure of the Formation is not exceeded. Regular monitoring of the water quality of 

21 the injected brine is required by the Permit, and pH would have to meet the respective upper 

22 control limits (UCLs) to be injected (WDEQ/WQD, 2011). The Permit also prohibits injection of 

23 hazardous waste as defined by EPA and WDEQ. Thus, the potential impacts of the Proposed 

24 Action’s operation to ground-water quantity and quality in the deep aquifers would be SMALL. 

25 The conditions of the UIC Permit would mitigate potential impacts, including those described 

26 above.

27

28 4.5.1.3 Ross Project Aquifer Restoration

29

30 The Proposed Action’s aquifer-restoration methodology would use a combination and sequence 

31 of: 1) ground-water transfer; 2) ground-water sweep; 3) reverse osmosis (RO), permeate 

32 injection, and recirculation; (4) stabilization; and (5) water treatment and surface conveyance. 

33 The Applicant proposes to use ground-water sweep selectively (i.e., around the perimeter of the 

34 wellfield) rather than throughout the entire wellfield to minimize the consumptive use of ground 

35 water (Strata, 2011a). After the first wellfield is depleted, the Applicant would conduct aquifer 

36 restoration concurrently with operation of subsequent wellfields. Consumptive use of ground 

37 water during the aquifer-restoration phase is generally greater than during uranium-recovery 

38 operation (NRC, 2009). 

39

40 Surface Water

41

42 As described in GEIS Sections 4.2.4.1.3 and 4.4.4.1.3, the activities occurring during aquifer 

43 restoration that could impact surface waters include management of waste water, permeate 

44 reinjection, storm-water runoff, and accidental spills and leaks (NRC, 2009). The GEIS 

45 concluded that the potential impacts to surface water due to the management of ground water 

46 extracted during aquifer restoration would be SMALL. An ISR operator’s compliance with permit 

47 conditions, use of BMPs, and execution of mitigation measures would reduce impacts from 

48 storm-water runoff as well as accidental spills and leaks such that they would be SMALL to 

49 MODERATE, depending upon site-specific conditions. 
DRAFT Environmental Impacts and Mitigation Measures

4-39

1 At the Ross Project, the Applicant intends to use approximately 13.6 L/min [3.6 gal/min] of water 

2 obtained from either the Oshoto Reservoir or the Little Missouri River for dust control during 

3 aquifer restoration (see Table 4.3). The potential impacts would thus be comparable to those 

4 during the Proposed Action’s construction and operation phases.

5

6 Potential increases in sediment concentrations during the Proposed Action’s aquifer-restoration 

7 phase would also be comparable to its operation phase. Potential risk of surface-water 

8 contamination associated with releases of process solutions and/or waste liquids as well as 

9 spills of other materials during aquifer restoration would be comparable to the operation phase 

10 of the Proposed Action, although the concentration of uranium-bearing solutions would decline. 

11 Thus, the potential impacts of aquifer restoration to surface-water quantity and quality would be 

12 SMALL. 

13

14 The potential impacts of aquifer restoration during the Proposed Action to the wetlands on the 

15 Ross Project area would be the same as discussed under the Ross Project’s construction.

16

17 Ground Water

18

19 As the GEIS states in Sections 4.2.4 and 4.4.4, the potential environmental impacts on ground20 water resources during aquifer restoration are related to ground-water consumptive use and 

21 waste-management practices, including liquid-effluent discharges to the surface impoundments 

22 and deep disposal of brine resulting from the RO process. In addition, aquifer restoration 

23 directly affects ground-water quality in the vicinity of the wellfield being restored (NRC, 2009).

24 The purpose of aquifer restoration is to return the ground-water quality in the production zone 

25 (i.e., the exempted ore zone) to ground-water protection standards specified at 10 CFR Part 40, 

26 Appendix A. These standards require that the concentration of a given hazardous constituent 

27 must not exceed 1) the NRC-approved background concentration of that constituent in ground 

28 water, 2) the respective numeric value in the table included in Paragraph 5C, if the specific 

29 constituent is listed in the table and if the background level of the constituent is below the value 

30 listed, or 3) an ACL the NRC establishes for the constituent. Potential impacts are affected by 

31 the aquifer-restoration methodologies chosen, the respective severity and extent of the 

32 contamination, and the current and future uses of the ore-zone and surrounding aquifers in the 

33 vicinity of an ISR facility. Consequently, the GEIS concluded that the potential impacts of 

34 ground-water consumption during aquifer restoration could range from SMALL to MODERATE, 

35 depending on site-specific conditions.

36

37 Shallow Aquifers

38

39 Potential impacts to water quantity of the shallow aquifers during restoration would be reduced, 

40 compared to the construction and operation phases of the Proposed Action. The impact to the 

41 aquifers’ water levels from consumptive use of water from the Oshoto Reservoir and the Little 

42 Missouri River would also be moderated, because of the lower-volume withdrawals from the 

43 surface-water bodies.

44

45 In addition, potential impacts to water quality would again be reduced when compared to the 

46 Proposed Action’s operation because no lixiviant would be used in the injection stream and the 

47 concentration of chemicals in the recovered ground water would be significantly less than during 

48 ISR operations. The Applicant’s implementation of BMPs during uranium-recovery operation 

49 would also reduce the likelihood and magnitude of spills and leaks, and thorough cleanup would 
DRAFT Environmental Impacts and Mitigation Measures

4-40

1 be facilitated. The ground-water mitigation measures during aquifer restoration would be the 

2 same as those described for the operation of the Proposed Action. Thus, the potential impacts 

3 of aquifer restoration to ground-water quantity and quality of the shallow aquifers would be 

4 SMALL.

5

6 Ore-Zone and Surrounding Aquifers

7

8 The magnitude of potential impacts to water quantity of the OZ aquifer and the surrounding 

9 aquifers during the aquifer-restoration phase of the Proposed Action would be greater than from 

10 its operation because of the greater consumptive use of ground water (Strata, 2011a). Ground11 water modeling estimates of the drawdown in the shallow-monitoring (SM) aquifer during both 

12 Ross Project operation and aquifer restoration were less than 5 m [15 ft]. The exempted OZ 

13 aquifer was predicted to experience significant drawdowns in three wells on the Ross Project 

14 area, with minor drawdowns in wells within 3.2 km [2 mi] of the Project. The conservative 

15 regional impact analysis conducted by the ground-water modeling predicts a reduction in the 

16 available head in wells used for stock, domestic, and industrial use. Although these effects 

17 would be localized and short-lived, the Applicant would commit to provide an alternative source 

18 of water of equal or better quantity and quality, subject to Wyoming water-statute requirements, 

19 in the event that aquifer-restoration operations prevent the full use of a well under a valid water 

20 right (Strata, 2011a; Strata, 2012a). Consequently, the potential impacts of the Proposed 

21 Action’s aquifer-restoration phase to ground-water quantity of the confined aquifers would be 

22 SMALL to MODERATE.

23

24 The potential for excursions during aquifer restoration that would affect water quality in the 

25 aquifers vertically adjacent to the exempted OZ aquifer would be similar to those described 

26 earlier for the Proposed Action’s operation. However, the magnitude of impacts would be less 

27 because the injection and recovery flow rates would be lower during aquifer restoration than 

28 during active uranium recovery and the ore-zone water quality would improve throughout active 

29 aquifer-restoration activities. The concentrations of radiological parameters and other chemical 

30 constituents in the permeate that would be injected as “clean” water to restore the exempted OZ 

31 aquifer would be lower than the pre-licensing baseline ore-zone water quality reported by the 

32 Applicant, except for radium-226 (Strata, 2011a). Dissolved radium-226 measured in the OZ 

33 aquifer has ranged from 0.03 Bq/L [0.71 pCi/L] to 0.44 Bq/L [12.01 pCi/L], and the typical 

34 radium-226 concentration is 1.1 Bq/L [30 pCi/L] (Strata, 2011a). The potential impacts of 

35 aquifer restoration to ground-water quality of the confined aquifers would be SMALL.

36

37 Deep Aquifers 

38

39 The Applicant estimates that less than 860 L/d [227 gal/d] of brine and other byproduct wastes 

40 would be disposed in the Class I injection wells during aquifer restoration at the Proposed 

41 Action. Although the volume of waste injected would be greater during the aquifer-restoration 

42 phase than during the Ross Project’s operation phase, the potential impacts would be similar 

43 because the injection pressures would not increase beyond the limit established by WDEQ’s 

44 UIC Permit. These pressure limits would ensure that the capacity of the Class I receiving 

45 aquifer is not exceeded. The potential impacts from aquifer restoration to ground-water quality 

46 of the deep aquifers would, therefore, be SMALL.
DRAFT Environmental Impacts and Mitigation Measures

4-41

1 4.5.1.4 Ross Project Decommissioning

2

3 The decommissioning activities of the Proposed Action that might impact surface water and/or 

4 ground water include the Applicant dismantling the CPP, auxiliary structures, and the surface 

5 impoundments; removing buried pipelines; excavating and removing any contaminated soil; 

6 plugging and abandoning wells using accepted practices; breaching the CBW; and restoring 

7 and revegetating all disturbed areas. Figure 4.1 indicates the components of the Proposed 

8 Action that would be in place by the end of its decommissioning.

9

10 Surface Water

11

12 As described in GEIS Sections 4.2.4 and 4.4.4, during the decommissioning phase, temporary 

13 impacts to water quality would be anticipated due to sediment loading during the excavation and 

14 removal of pipelines, drainage crossings, and other infrastructure (NRC, 2009). As the GEIS 

15 noted, an Applicant’s compliance with permit conditions, its use of BMPs, and its observance of 

16 required mitigation measures would reduce decommissioning impacts to SMALL to 

17 MODERATE, depending upon site-specific conditions. 

18

19 For the Proposed Action, the Applicant intends to use surface water from either the Oshoto 

20 Reservoir or the Little Missouri River for dust control and any demolition activities during the 

21 Project’s decommissioning. As shown in Table 4.3, the Applicant estimates that approximately 

22 42 L/min [11 gal/min] of surface water would be used during facility and wellfield 

23 decommissioning. This withdrawal rate is between the quantities of anticipated water use 

24 during the Proposed Action’s construction and operation phases.

25

26 The primary impacts to surface water during the decommissioning of the Ross Project would be 

27 from activities associated with the removal of constructed Project components, reclamation and 

28 restoration of the land impacted during the Proposed Action, and the cleanup of any 

29 contaminated soils. These impacts would be similar to those that result from the construction of 

30 the Proposed Action. Removal of buried pipelines and the roads near stream channels during 

31 the decommissioning phase would result in temporary disturbances that could impact surface32 water quality. Potential surface-water contamination could occur from spilled or leaked fuel or 

33 lubricants from construction equipment and passenger vehicles that would be operated during 

34 decommissioning activities, although the equipment would generally be located away from 

35 surface-water bodies. These potential impacts to surface-water quality would be mitigated 

36 using the same measures as implemented during the Proposed Action’s construction (e.g., 

37 BMPs and spill-response protocols). The potential impacts to surface-water quantity and quality 

38 from the Ross Project’s decommissioning would be SMALL.

39

40 The potential impacts to wetlands from the Proposed Action’s decommissioning would be 

41 SMALL, as they would be the same as discussed under the Proposed Action’s construction.

42

43 Ground Water

44

45 As described in GEIS Sections 4.2.4 and 4.4.4, the impacts to ground water during the 

46 decommissioning of an ISR facility are primarily associated with consumptive use of ground 

47 water, potential spills of fuels and lubricants, and well abandonment (NRC, 2009). Ground48 water consumptive use during decommissioning activities would be less than during operation 

49 and aquifer-restoration activities. BMPs would reduce the likelihood of spills and leaks. After 
DRAFT Environmental Impacts and Mitigation Measures

4-42

1 ISR operations are completed and a facility is decommissioned, improperly abandoned wells 

2 could impact aquifers above the OZ aquifer by providing hydrological connections between 

3 aquifers (NRC, 2009). To ensure that this consequence does not happen at the Ross Project, 

4 all injection, recovery, and monitoring wells would be plugged and abandoned in accordance 

5 with UIC Permit requirements. The GEIS determined that implementation of BMPs and 

6 compliance with permit requirements would ensure that the potential impacts to ground water 

7 would be SMALL during decommissioning; the Proposed Action’s decommissioning would 

8 include observance of these procedures and requirements.

9

10 Shallow Aquifers

11

12 During decommissioning, finger drains (see SEIS Section 2.1.1.4) would be created along the 

13 up-gradient and down-gradient sides of the CBW and backfilled with permeable material

14 (gravel). These gravel-filled breaches in the CBW would create a highly permeable flow path 

15 through the CBW that would allow the natural flow of the shallow aquifer ground water beneath 

16 the CPP and in the immediate vicinity outside the CBW to be restored. Water levels would be 

17 monitored by the Applicant to verify that the CBW reclamation and ground-water restoration is 

18 complete. After uranium-recovery operation is complete, unidentified, improperly abandoned 

19 wells (i.e., from previous subsurface explorations not associated with the Applicant or its 

20 operations) could continue to impact aquifers above the ore-zone and adjacent aquifers by 

21 providing hydrologic connections between aquifers. The Applicant’s implementation of BMPs 

22 and SOPs for the plugging and abandonment of its own wells during decommissioning of the 

23 Proposed Action would reduce the likelihood of shallow-aquifer contamination. In addition, 

24 other BMPs employed by the Applicant would reduce the likelihood and magnitude of spills and 

25 leaks during equipment and vehicular operation and would facilitate any soil or other cleanup 

26 required. Thus, the impacts to shallow aquifers during the Proposed Action’s decommissioning 

27 would be SMALL. 

28

29 Ore-Zone and Surrounding Aquifers

30

31 As part of the decommissioning of the Proposed Action and the concomitant land reclamation 

32 and restoration activities, all monitoring, injection, and production wells would be plugged and 

33 abandoned in accordance with the UIC Permit requirements. The wells would be filled with 

34 cement and/or bentonite and then cut off below plow depth to ensure ground water does not 

35 flow through the abandoned wells (Stout and Stover, 1997). Proper implementation of these 

36 procedures would isolate the wells from ground-water flow. Thus, the impacts to the ore-zone 

37 and vertically adjacent aquifers would be SMALL.

38

39 Deep Aquifers 

40

41 The Applicant estimates that less than 38 L/day [10 gal/day] of brine and other liquid byproduct 

42 wastes would be disposed in the Class I injection wells during the decommissioning of the 

43 Proposed Action. The potential impacts to ground-water quantity and quality during 

44 decommissioning would be SMALL and less than the other phases of the Ross Project.

45

46 4.5.2 Alternative 2: No Action

47

48 Under the No-Action Alternative, the Ross Project would not be licensed and the land would 

49 continue to be available for other uses. Mud pits that could continue to be constructed at each 
DRAFT Environmental Impacts and Mitigation Measures

4-43

1 well site to manage drilling fluids and muds would have little potential of impacting surface 

2 waters and no potential of impacting ground water. The roads across the Ross Project area 

3 would be graded, contoured, and revegetated, also leaving little potential for them to impact 

4 surface water by increasing sediments. 

5

6 Similarly, although no license would be issued and no Ross Project would be constructed or 

7 operated in the No-Action Alternative, preconstruction activities would cause potential impacts. 

8 The respective impacts to ground water depend upon the density of plugged and abandoned 

9 wells and drillholes. As of August 2011, the Applicant had drilled and plugged approximately 

10 612 holes it installed during site and geotechnical characterization; an additional 51 were drilled 

11 and are now used as site-characterization ground-water monitoring wells. The Applicant has 

12 also located and properly abandoned 55 Nubeth drillholes. Thus, the drillhole density is 

13 approximately 1 hole per 1 ha [2.5 ac]. Under the No-Action Alternative, the 51 monitoring 

14 wells, and any others that could be located, would need to be properly abandoned, where each 

15 well and drillhole would be filled with a concrete plug up to 6 inches in diameter through the 

16 entire depth of the hole. The low density of these properly plugged and abandoned wells and 

17 drillholes would not affect the ground-water flow or quality.

18

19 Thus, the potential impacts from the No-Action Alternative to surface and ground waters, 

20 relative to the existing Ross Site area and including the preconstruction activities that have 

21 already occurred, would be SMALL

22

23 4.5.3 Alternative 3: North Ross Project

24

25 Under Alternative 3, the North Ross Project would generally be the same as the Proposed 

26 Action, except that the facility (i.e., the CPP, associated buildings, and auxiliary structures as 

27 well as the surface impoundments) would be located to the north of where it would be located in 

28 the Proposed Action, as described in SEIS Section 2.1.3. The hydrology of the north site differs 

29 from that under the location of the CPP in the Proposed Action. The depth to the unconfined, 

30 shallow ground-water aquifer is greater, which would eliminate the need for a CBW. However, 

31 the north site contains two ephemeral streams rather than the one in the Proposed Action. 

32 These ephemeral drainages extend over 760 m [2,500 ft], before entering the Little Missouri 

33 River, compared to the Proposed Action where the facility is within 300 m [1,000 ft] of the 

34 Oshoto Reservoir and the Little Missouri River. Because of the drainage, the design of the 

35 facility could require that the CPP and the surface impoundments be constructed across a 

36 drainage that leads directly to the Little Missouri River. The ground’s surface slopes to the 

37 southeast at a grade of 5 – 15 percent compared with a slope of less than 1 percent for the 

38 south location in the Proposed Action. Thus, the construction of the surface impoundments on 

39 the steeper slope would require a large increase in the area of disturbed land and would require

40 that significant design and engineering considerations be addressed in order to mitigate 

41 potential impacts to surface water.

42

43 Nonetheless, most of the potential impacts of and mitigation measures for this Alternative would 

44 be the same as for the Proposed Action. Only the differences in impacts between the Proposed 

45 Action and the North Ross Project are described below.
DRAFT Environmental Impacts and Mitigation Measures

4-44

1 4.5.3.1 North Ross Project Construction

2

3 Impacts to surface and ground waters during construction are expected to be generally the 

4 same as the Proposed Action, although the steeper slopes at the north site would require more 

5 engineering and construction activity. As a result, there would be a slight increase in the 

6 potential for impacts to surface and ground waters in the shallow aquifer. However, the impacts 

7 to shallow ground water in the Proposed Action, which result from the construction of the CBW 

8 and, in particular, the alteration of the surficial ground-water flow regime, would not be a 

9 consequence of this Alternative. At the north site, shallow ground-water levels are estimated to 

10 be at a depth of greater than 15 m [50 ft], within the sandstones of the LA interval of the Lance 

11 Formation (as discussed in SEIS Section 3.4); however, during high-precipitation events or after 

12 significant snowmelt, perched ground water could be present above the regional water table. If 

13 the CBW is not needed and not constructed by the Applicant, then the need for dewatering the 

14 shallow aquifer would be eliminated and thereby would reduce the consumption of ground water 

15 by a small amount. 

16

17 Construction of the storm-water control system and implementation of BMPs during construction 

18 of the Alternative 3 facility would be more involved, in order to protect the two ephemeral 

19 drainages from impacts of erosion and increased sediment loads. If the Alternative 3 design 

20 required the CPP and the surface impoundments to be separated by a drainage (as shown in 

21 Figure 2.11 in SEIS Section 2.1.3), the construction of the pipeline network would also require 

22 additional construction and engineering activity. However, the BMPs during construction would 

23 minimize potential impacts to surface and ground waters from construction of Alternative 3; 

24 thus, the impact would still be SMALL.

25

26 4.5.3.2 North Ross Project Operation

27

28 Alternative 3 would result in many of the same potential impacts to surface water during its 

29 operation as the Proposed Action’s. The proximity of the facility to two ephemeral drainages 

30 would increase the risk of surface-water impacts from spills and leaks, where the released 

31 material could make its way into surface water. The potential for impact to surface water would 

32 be mitigated by the distance of approximately 0.8 km [0.5 mi] to the Little Missouri River. The 

33 greater distances from the CPP to the Little Missouri River in Alternative 3, when compared to 

34 those of the Proposed Action, would also strengthen the natural mitigation of impacts from 

35 discharge of excess permeate. Operation of the wellfields during the North Ross Project would 

36 be the same as during the Proposed Action and, therefore, the potential impacts and mitigation 

37 measures associated with the wellfields would be the same. Thus, the potential impacts to 

38 surface water of Alternative 3’s operation would be SMALL.

39

40 The greater thickness of the vadose (i.e., unsaturated) zone under the north site would also 

41 provide additional natural protection to the shallow ground water in the event of a release of 

42 process chemicals, recovery solutions, or liquid wastes within the CPP and surface43 impoundment areas. If contaminants reached the ground water, remediation by pump-and-treat 

44 methods would be required. With the Proposed Action, ground-water levels within the CBW 

45 would be maintained lower than surrounding and underlying ground-water levels, and would 

46 thus prevent any migration of contaminants away from the CPP and surface impoundments. 

47 Because there would be no difference between the location and operation of the wellfields 

48 under Alternative 3 as compared with the Proposed Action, the potential MODERATE impacts 

49 from lixiviant excursions discussed in SEIS Section 4.5.1.2 could also occur under Alternative 3. 
DRAFT Environmental Impacts and Mitigation Measures

4-45

1 Therefore, the potential impacts to ground water of the operation of Alternative 3 would be 

2 SMALL to MODERATE due to the potential for lixiviant excursions.

3

4 4.5.3.3 North Ross Project Aquifer Restoration

5

6 Because the wellfields would be in the same locations in Alternative 3, this Alternative does not 

7 include any modifications to the wellfields from what was described for the Proposed Action 

8 (because they follow the subsurface uranium mineralization), the wellfields would result in the 

9 same potential impacts to ground water during Alternative 3’s aquifer restoration phase as in the 

10 Proposed Action. These potential impacts would be SMALL to MODERATE, due to potential 

11 drawdowns during aquifer restoration.

12

13 4.5.3.4 North Ross Project Decommissioning

14

15 Alternative 3 would result in generally the same potential impacts to surface and ground waters 

16 during its decommissioning as would the Proposed Action, with the following exceptions: The 

17 surface-impoundment area requiring recontouring and revegetation would be larger and more 

18 extensive; thus, the potential for surface-water impacts associated with these activities would be 

19 marginally greater. Unlike with the Proposed Action, it would not be necessary to cut gravel20 filled channels through a CBW, thereby eliminating the potential for the associated surface21 water impacts. The potential impacts during Alternative 3’s decommissioning to the surface 

22 drainages through the north site would be the same as described above for Alternative 3’s 

23 operation. The potential impacts to surface and ground waters from decommissioning of 

24 Alternative 3 would be SMALL.

25

26 4.6 Ecology 

27

28 The Proposed Action could impact ecological resources, including both flora and fauna during 

29 all phases of the Project’s lifecycle. These impacts could include removal of vegetation from the 

30 Ross Project area; reduction in wildlife habitat and forage productivity, and an increased risk of 

31 soil erosion and weed invasion; the modification of existing vegetative communities; the loss of 

32 sensitive plants and habitats; and the potential spread of invasive species and noxious weed 

33 populations. Impacts to wildlife could include loss, alteration, or incremental fragmentation of 

34 habitat; displacement of and stresses on wildlife; and direct and/or indirect mortalities. Aquatic 

35 species could be affected by disturbance of stream channels, increases in suspended 

36 sediments, pollution from fuel spills, and habitat reduction. The potential environmental impacts 

37 to and related mitigation measures for ecological resources during the construction, operation, 

38 aquifer restoration, and decommissioning of the Proposed Action and the two Alternatives are 

39 discussed in the following sections.

40

41 4.6.1 Alternative 1: Proposed Action

42

43 Alternative 1, the Proposed Action, consists of four phases: construction, operation, aquifer 

44 restoration, and decommissioning of an ISR uranium-recovery facility and wellfields.

45

46 4.6.1.1 Ross Project Construction

47

48 As discussed in GEIS Section 4.4.5, the potential impacts to terrestrial vegetation during the 

49 construction of ISR facilities could include removal of vegetation from ISR facility sites (and the 
DRAFT Environmental Impacts and Mitigation Measures

4-46

1 associated reduction in wildlife habitat and forage productivity and the increased risk of soil 

2 erosion and weed invasion), the modification of existing vegetative communities, the loss of 

3 sensitive plants and habitats as a result of site clearing and grading, and the potential spread of 

4 invasive species and noxious weed populations (NRC, 2009). 

5

6 The construction phase of the Proposed Action could potentially impact the local ecology during 

7 the Applicant’s clearing vegetation and leveling the site; constructing the CPP, auxiliary 

8 structures, and surface impoundments; developing the wellfields, including drilling wells, laying 

9 pipelines, constructing header houses, and other wellfield components; constructing access 

10 roads; clearing storage, parking, and laydown areas; and installing associated infrastructures 

11 such as utility and lighting systems. The ecological impacts of these construction activities are 

12 evaluated for protected species, vegetation, and wildlife.

13

14 Terrestrial Species

15

16 Vegetation

17

18 The construction of the Ross Project facility (i.e., CPP and surface impoundments) as well as 

19 the installation of wellfields would take place within the nine vegetation communities present at 

20 the Project area (upland grassland, sagebrush shrubland, pastureland, hayland, reservoir/stock 

21 pond, wetland, disturbed land, cropland, and wooded draw) (see SEIS Section 3.2). Direct 

22 impacts of such construction would include the short-term loss of vegetation (structure 

23 modification, species composition, and areal extent of cover types). An estimated 113 ha [280 

24 ac] of land disturbance would occur; one-half of this disturbance would occur within the upland 

25 grassland vegetation community, primarily because of wellfield-module and access-road 

26 construction. 

27

28 Only 7 percent of the Ross Project area is currently hayland; however, 20 – 30 percent of the 

29 impacts would be to this vegetation community because of construction of the CPP and surface 

30 impoundments. Indirect impacts include the short-term and long-term increased potential for 

31 non-native species invasion, establishment, and expansion; exposure of soils to accelerated 

32 erosion; shifts in species composition or changes in vegetation density; reduction of wildlife 

33 habitat; and reduction in livestock foraging opportunities. 

34 Sagebrush shrubland, the second largest vegetation type on the Ross Project area, can be 

35 difficult and time-consuming to re-establish. Consequently, preconstruction vegetation 

36 communities and sub-communities (i.e., shrub-steppe) may be different than post-construction 

37 communities (i.e., grass-dominated) for several years, or possibly decades, which could alter 

38 the composition and abundance of both plant and wildlife species in the area. Site reclamation 

39 and/or regeneration of native shrub species could be further hindered by year-long grazing 

40 pressure. Large ungulates (i.e., wild and domestic animals with hooves) are attracted to the 

41 more succulent, younger plants, and they often concentrate in newly seeded locations during 

42 the critical early-growth stage. Impacts to the sagebrush-shrubland vegetation type would be 

43 minimized by the Applicant reducing surface disturbance where possible, distributing a 

44 temporary seed mixture to prevent invasion of non-native species in disturbed areas, restoring 

45 sagebrush and other shrubs on reclaimed lands, and conducting all re-vegetation activities in 

46 accordance with an approved WDEQ/LQD reclamation plan (Strata, 2011b).
DRAFT Environmental Impacts and Mitigation Measures

4-47

1 Construction activities, including the increased soil disturbance and increased traffic during 

2 construction, could stimulate the introduction and spread of undesirable and invasive, non3 native species at the Ross Project area. Several species of designated and prohibited noxious 

4 weeds listed in the Wyoming Weed and Pest Control Act were identified on the Ross Project 

5 area. These species included field bindweed, perennial sow thistle, quack grass, Canada 

6 thistle, hounds tongue, leafy spurge, common burdock, Scotch thistle, Russian olive, and 

7 skeletonleaf bursage (Strata, 2011a). These species could be locally abundant in small areas, 

8 especially around the Oshoto Reservoir and along the Little Missouri River and Deadman 

9 Creek, but they were not common over the entire Ross Project area. 

10

11 The impact from vegetation removal and surface disturbance would affect approximately 113 ha 

12 [280 ac] of land, or about 16 percent of the Proposed Action’s area. Construction would be 

13 phased over time, further reducing the amount of surface area disturbed at any one time. 

14 Noxious weeds would be controlled with appropriate spraying techniques. Therefore, the 

15 impacts to terrestrial vegetation would be SMALL.

16

17 In addition, the potential impacts to vegetation during the Proposed Action’s construction would 

18 be mitigated by the Applicant’s ensuring that disturbed areas would be both temporarily and 

19 permanently revegetated in accordance with WDEQ/LQD regulations and its WDEQ Permit to 

20 Mine. The Applicant would seed disturbed areas to establish a vegetative cover to minimize 

21 wind and water erosion and the invasion of undesirable plant species. The impacts would be 

22 further mitigated by a phased approach to construction, and therefore surface disturbance 

23 would be phased. A temporary seed mix could be used in wellfields and other areas where the 

24 vegetation would be disturbed again prior to final decommissioning and final revegetation. The 

25 temporary seed mix typically would consist of one or more of the native wheatgrasses (e.g., 

26 western wheatgrass and thick-spike wheatgrass). Permanent seeding is accomplished with a 

27 seed mix approved by the WDEQ/LQD and with County conservation district requirements. 

28 Two permanent reclamation seed mixtures (upland and pastureland/hayland) would be used to 

29 reseed disturbed areas. Wellfield areas would be fenced as necessary to prevent livestock 

30 access, which would also enhance the establishment of temporary vegetation (Strata, 2011a). 

31 The Applicant would conduct weed control as needed to limit the spread of undesirable and 

32 invasive, non-native species on disturbed areas (Strata, 2011a).

33 Wildlife

34

35 As discussed in GEIS Section 4.4.5, in general, wildlife species would disperse from an area 

36 undergoing construction, although smaller, less-mobile species could perish during clearing and 

37 grading. Habitat fragmentation, temporary displacement, and direct or indirect mortalities are 

38 possible, and thus the GEIS concluded that construction impacts on wildlife could range from 

39 SMALL to MODERATE (NRC, 2009). These types of impacts could be mitigated during the 

40 Proposed Action if standard management practices suggested by the WGFD were to be 

41 followed. Moreover, impacts on raptor species from power distribution lines could be mitigated 

42 by the Applicant’s following the Avian Power-Line Interaction Committee (APLIC) guidance and 

43 avoiding disturbance of areas near active nests and prior to the fledging of young (APLIC, 

44 2006).
DRAFT Environmental Impacts and Mitigation Measures

4-48

1 Mammals

2

3 The Ross Project area provides year-long range to pronghorn antelope, and winter/year-long 

4 range for mule deer, but it is considered outside of the normal range for white-tailed deer and 

5 elk (see SEIS Section 3.6.1). White-tailed deer, however, were observed during the Applicant’s 

6 wildlife surveys as were pronghorn antelope. No crucial big-game habitats or migration 

7 corridors are recognized by the WGFD at the Ross Project area or the surrounding 1.6-km [1-

8 mi] perimeter. (A crucial range or habitat is defined as any particular seasonal range or habitat 

9 component that has been documented as the determining factor in a population’s ability to 

10 maintain and reproduce itself at a certain level.) Therefore, there would be no direct impact on 

11 big-game’s crucial habitat, critical or key winter or summer ranges, or migration corridors. Direct 

12 impacts on white-tailed deer and elk could include direct loss and modification of habitat, 

13 increased mortality from increased traffic collisions on local and regional roads, increased 

14 competition for and reduction of available forage, increased conflicts with vehicles because of 

15 changes in wildlife movement patterns, and increased disturbance due to the presence of 

16 humans. White-tailed deer and elk could be indirectly affected during construction by displacing 

17 portions of these populations from the Ross Project area into offsite suitable regional habitat. 

18 Because the Project area provides only nonessential habitat for white-tailed deer and elk, 

19 impacts to these species would be SMALL. 

20

21 The direct impacts on pronghorn antelope and mule deer could be the same as those described 

22 previously for white-tailed deer and elk. The construction phase of the Proposed Action has 

23 been estimated to last 12 months. Adequate habitat for pronghorn antelope and mule deer 

24 exists in the surrounding area, and these species could return to the areas affected by 

25 construction when the activities are complete. The staged restoration of disturbed areas that 

26 the Applicant proposes would provide grass and forage within a few years of habitat 

27 disturbance. The movement of big game through the Ross Project would not be significantly 

28 impacted by the Proposed Action. The Applicant has committed to implementing mitigation 

29 measures, such as reduced speed limits to reduce the risk of vehicular collision, fences 

30 designed to permit big game passage, and use of existing roads where possible to avoid 

31 altering wildlife movement patterns. Because pronghorn antelope and mule deer are highly 

32 mobile species, the potential impact to these species would be SMALL.

33

34 A variety of small- and medium-sized mammals are also potentially found on the Ross Project 

35 area (see SEIS Section 3.6.1) (Strata, 2011a). These include a variety of predators and 

36 furbearers, such as coyote, red fox, raccoon, bobcat, badger, beaver, and muskrat. Prey 

37 species observed during the Applicant’s field surveys included rodents (e.g., mice, rats, voles, 

38 gophers, ground squirrels, and chipmunks), jackrabbits, and cottontails. These species are 

39 cyclically common and widespread throughout the region and are important food sources for 

40 raptors and other predators. 

41

42 Medium-sized mammals (e.g., coyotes, foxes) could be temporarily displaced to other habitats 

43 during construction activities. Direct losses of limited-mobility, small-mammal species (e.g., 

44 voles, ground squirrels, mice) could be higher than for other wildlife because of the likelihood 

45 they would retreat into burrows if disturbed, and thus potentially be killed by topsoil scraping or 

46 staging activities. However, given the limited, noncontiguous area that would be disturbed 

47 (approximately 113 ha [280 ac]), no major changes or reductions in small- or medium-sized 

48 mammal populations would be expected. The species that occur in the area have shown an 

49 ability to adapt to human disturbance in varying degrees, and each also has a high reproductive 
DRAFT Environmental Impacts and Mitigation Measures

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1 potential and tend to re-occupy and adapt to altered or reclaimed areas quickly. Because only a 

2 few individuals would be affected, and most mammal species would likely travel to suitable 

3 habitat near the Ross Project area during its construction, the Proposed Action would have a 

4 SMALL impact on these mammals.

5

6 Birds

7

8 Potential impacts to upland game birds at the Ross Project area include nest destruction or nest 

9 desertions, reproductive failure as a result of proposed construction activities and increased 

10 presence of humans, or increased mortalities associated with traffic. Four upland game-bird 

11 species occur within or near the Ross Project area (i.e., wild turkey, sage-grouse, sharp-tailed 

12 grouse, and mourning doves) (Strata, 2011a). Suitable habitat (for nesting, brood-rearing, and 

13 foraging) for these four species exists in the Ross Project area; however, as previously 

14 discussed, there are no sage-grouse core areas or connectivity corridors within the Project area. 

15 Because of the type of disturbance (the relatively small areas of disturbance and the sequential 

16 nature of the disturbance), impacts to upland game birds as a result of the Proposed Action 

17 would be SMALL.

18

19 Potential impacts to raptors within the Ross Project area also include nest desertions or 

20 reproductive failure as a result of construction activities and increased presence of humans; 

21 temporary reductions in prey populations; and mortality associated with traffic. Six raptor 

22 species on the USFWS SMC list (i.e., bald eagle, Swainson’s hawk, ferruginous hawk, golden 

23 eagle, prairie falcon, and short-eared owl) have been observed within or near the Project area 

24 (Strata, 2011a). Swainson’s and ferruginous hawks are the only species known to nest in the 

25 area. One intact raptor nest (a Swainson’s hawk nest, No. SH1) was located at the Ross 

26 Project area during the Applicant’s field surveys. Seven intact nests and one nest no longer 

27 intact were located with 1.6 km [1 mi] of the Project area. The nest within the Ross Project area 

28 would not be directly disturbed during the Proposed Action’s construction, so nesting raptors 

29 would not be directly impacted. Foraging raptors are expected to be able to avoid any areas of 

30 disturbance. Because of the type of disturbance (again, the relatively small areas of 

31 disturbance and the sequential nature of the disturbance) and the fact that no raptor nests 

32 would be directly affected, impacts to raptors during the Proposed Action would be SMALL.

33

34 Potential impacts to nongame or migratory birds within the Ross Project area include nest 

35 destruction or desertions, or reproductive failure as a result of construction activities during the 

36 Proposed Action. Increased mortality associated with the increased traffic during the 

37 construction phase could also occur. The field surveys completed by the Applicant identified 27 

38 nongame or migratory avian species within the Ross Project area (Strata, 2011a). Because of 

39 the type and sequence of land disturbance, the Proposed Action’s construction impacts to 

40 nongame or migratory birds would be SMALL.

41

42 Thus, all impacts to terrestrial wildlife would be SMALL.

43

44 Reptiles, Amphibians, and Aquatic Species

45

46 Potential impacts to reptiles, amphibians, and fish during construction of the Proposed Action 

47 would primarily be the result of the mortality of individuals and destruction of habitat. Sediment 

48 loads in surface waters and wetlands from surface-disturbing activities could also potentially 

49 impact aquatic habitat, although potential impacts would be greatly reduced through sediment-
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1 control BMPs. Up to 0.8 ha [2 ac] of wetland habitat could be disturbed as a result of 

2 construction; however, all wetland disturbance would be mitigated in accordance with USACE 

3 requirements found in the CWA permit. 

4

5 Because of the type of disturbance, which would be relatively small, and the sequential nature 

6 of the disturbance as well as the fact that aquatic habitats would be avoided if at all possible 

7 during construction, impacts to reptiles, amphibians, and fish during the Proposed Action would 

8 be SMALL.

9

10 Protected Species 

11

12 As discussed in SEIS Section 3.6.1.4, a protected species of bird, the Greater sage-grouse 

13 could occur on the Ross Project area. The nearest active sage-grouse lek (i.e., Cap’n Bob), a 

14 mating-strutting area for male sage-grouse, is located approximately 3.5 km [2.2 mi] southeast 

15 of the Ross Project area. There is also an inactive-status lek (for 2010) within 1.6 km [1 mi] of 

16 the Project’s boundary. Wyoming policy states that surface-disturbing and/or disruptive 

17 activities are prohibited or restricted from March 15 through June 30. This restriction is typically 

18 only applied to suitable sage-grouse nesting and early brood-rearing habitat, within mapped 

19 habitat important for connectivity, or within 3 km [2 mi] of any occupied or “undetermined lek.” 

20 The leks observed by the Applicant are outside of the Proposed Action area and are not located 

21 in proximity to any proposed construction or operation activities at the Proposed Action. 

22 However, if a Greater-sage-grouse lek were to be identified within the Ross Project area at any 

23 time during the Ross Project, including construction, the Applicant would follow WGFD policy 

24 regarding construction-activity restrictions. The Applicant would continue to consult with WGFD 

25 and WDEQ/LQD to determine if a sage-grouse monitoring, protection, and habitat enhancement 

26 plan would be necessary for the Ross Project, and a plan would be developed and 

27 implemented, if warranted. 

28

29 During the Applicant’s field surveys, the northern leopard frog was the only U.S. Bureau of Land 

30 Management (BLM)-listed reptile, amphibian, or fish sensitive species actually observed in the 

31 Ross Project area; three amphibian and five reptile Wyoming SOC were observed (Strata, 

32 2011a). Impacts to protected avian, amphibian, and reptile species would be no different than 

33 those for other similar species because the Applicant would observe appropriate activity 

34 restrictions, attempt to avoid aquatic habitats during road construction, and implement the 

35 mitigation measures below.

36 The potential impacts to ecological resources associated with construction activities during the 

37 Proposed Action would be limited due to the relatively small area of surface disturbance. 

38 Nevertheless, mitigation measures to prevent or further reduce impacts to wildlife would include 

39 one or more of the following, as addressed by the various regulatory and permit-issuing 

40 agencies:

41

42 ■ Design of fencing to permit big-game passage as required by the WGFD.

43 ■ Use of existing roads when possible and location of newly constructed roads to access more 

44 than one well location according to BLM requirements.
DRAFT Environmental Impacts and Mitigation Measures

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1 ■ Implementation of speed limits to minimize collisions with wildlife, especially during the 

2 breeding season, according to a MOU between the Applicant and Crook County 

3 transportation authorities (Strata, 2011d).

4 ■ Adherence to temporal and spatial restrictions within specified distances of active sage5 grouse leks as determined through consultation with the WGFD and the WDEQ/LQD.

6 ■ If direct impacts to raptors or migratory-bird SMC result from construction, a monitoring and 

7 mitigation plan (MMP) for those species would be prepared and approved by the USFWS, 

8 and would include one or more of the following provisions:

9 ■ Relocation of active and inactive raptor nests that would be impacted by well drilling and 

10 other construction activities in accordance with the approved raptor MMP

11 ■ Institution of buffer zones to protect raptor nests where necessary and restriction of 

12 uranium-recovery-related disturbances from encroaching within buffers around active 

13 raptor nests (from egg-laying until fledging) to prevent nest abandonment or injury to 

14 eggs or young

15 ■ Restoration of the ground cover necessary to attract and sustain a suitable raptor-prey 

16 base after drilling, construction, and future uranium-recovery activities, and

17 ■ Requirement for the use of raptor-safe construction for overhead power lines according 

18 to current guidelines and recommendations by the APLIC and/or the USFWS.

19 ■ Restoration of sagebrush and other shrubs on reclaimed lands and grading of reclaimed 

20 areas to create swales and depressions for sagebrush obligates (sagebrush obligates are 

21 those species that need sagebrush to survive, e.g., sage grouse) and their young per 

22 WDEQ/LQD requirements.

23 ■ Restoration of preconstruction, native habitats for species that nest and forage in those 

24 vegetative communities according to WDEQ/LQD and WGFD requirements.

25 ■ Restoration of diverse landforms, replacement of topsoil, and the construction of brush piles, 

26 snags, and/or rock piles to enhance habitat for wildlife per WDEQ/LQD requirements.

27 ■ Restoration of habitat provided by jurisdictional wetlands as required by both the 

28 WDEQ/LQD and the USACE.

29 Thus, with the measures listed above, the environmental impacts to terrestrial, aquatic, and 

30 protected species during Ross Project construction would be SMALL.

31

32 4.6.1.2 Ross Project Operation

33

34 As discussed in GEIS Section 4.4.5, alteration of wildlife habitats could result from uranium35 recovery activities (e.g., fencing, traffic, and noise), and conflicts between species habitat and 

36 uranium-recovery activities could occur (NRC, 2009). The GEIS further noted the occurrence of 

37 temporary contamination of soils from spills and leaks during ISR operation. However, rapid 

38 discovery and response to spills and leaks (i.e., spill containment and cleanup of potentially 

39 impacted soil), and the eventual survey for radiation during decommissioning, would limit the 

40 magnitude of overall impacts to terrestrial ecology during the Proposed Action’s operation. 

41 Leak-detection systems and spill-response plans would reduce the potential impacts to aquatic 
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1 species from spills around wellheads and leaks from pipelines by preventing contamination of 

2 soils, surface waters, or wetlands. Additional mitigation measures such as perimeter fencing, 

3 surface-impoundment netting or other avian deterrents, and periodic wildlife surveys would also 

4 limit impacts during the Proposed Action’s operation.

5

6 Terrestrial Species

7

8 Vegetation

9

10 During the operation phase of the Proposed Action, the wellfields and CPP would be frequently 

11 accessed by use of the existing roads. The installation and operation of the wellfields would 

12 involve the excavation of trenches for trunk lines and utilities; this surface disturbance would 

13 increase the susceptibility of the disturbed area to invasive and noxious weeds. However, 

14 surface disturbance would continue to be minimized during operation as new, additional 

15 wellfields are installed, and vehicular access would be restricted to specific roads. The potential 

16 for these impacts to occur during operations is less than that during construction, due to fewer 

17 hectares or acres of land being disturbed. There is a potential for impacts to vegetation from 

18 spills around wellheads and leaks from pipelines during the Ross Project’s operation. Based 

19 upon the small amount of land that would be disturbed during operation, and the lower number 

20 of vehicles accessing the Ross Project, the impacts would be SMALL during the operation 

21 phase of the Proposed Action.

22

23 Wildlife

24

25 Wildlife use of areas adjacent to and near the Proposed Action would likely initially decline 

26 because of human presence during the Project’s operation and steadily increase to near-normal 

27 levels once animals become habituated to the uranium-recovery activities. Because wildlife 

28 could be in fairly close proximity to the CPP, surface impoundments, wellfields, and roads, some 

29 impacts to wildlife would be expected from direct conflict with vehicular traffic and the presence 

30 of Strata’s onsite personnel. In addition, wildlife could be exposed to contaminated soil resulting 

31 from spills and leaks. All of these impacts would be SMALL, however, because only a few 

32 individual animals would be affected, the potential for spills and leaks is low, and the continued 

33 existence of any particular species at the Ross Project area would not be affected. Potential 

34 impacts to terrestrial wildlife during the Ross Project’s operation phase from process waste 

35 water and sediment in the facility’s lined surface impoundments would be reduced by the 

36 fencing that would be installed around the entire facility (i.e., around the CPP and the surface 

37 impoundments) (see Figure 3.1 in SEIS Section 3.2). Therefore, during the operation of the 

38 Proposed Action, the potential impacts to wildlife would be SMALL.

39

40 Mammals

41

42 The potential impact to big game during the Proposed Action’s operation phase would either be 

43 similar to or less than that described earlier for the construction phase, because limited earth44 moving activities would occur. Therefore, there would be only SMALL impacts to big game 

45 species during the operation phase of the Proposed Action. The potential impacts to other 

46 mammals during operation of the Ross Project would also be similar to or less than that 

47 described earlier for the construction phase. Because only a few individual mammals would be 

48 affected, and most mammal species would likely travel to suitable habitat outside of the 
DRAFT Environmental Impacts and Mitigation Measures

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1 operating facility and wellfields, the Proposed Action would have SMALL impacts on these 

2 mammals during its operation. 

3

4 Birds

5

6 The potential impacts to upland game birds, waterfowl, shorebirds, and raptors during the 

7 Proposed Action’s operation would either be the same or less than that described earlier for the 

8 construction phase because earth-moving activities would be more limited during its operation 

9 phase. 

10

11 For avian control at the surface impoundments, the Applicant is considering three options, 

12 including netting, “bird balls” (hollow or water-filled balls), or a radar-hazing system (Strata, 

13 2012a). Following an extensive literature review and contact with knowledgeable individuals 

14 regarding avian deterrents for impoundments, a radar-hazing system has been identified by the 

15 Applicant as the most likely solution for its deterring avian species from the surface 

16 impoundments associated with uranium-recovery activities. This system uses radar to detect 

17 incoming waterfowl and then uses hazing techniques (primarily noise) to scare the birds away. 

18 The avian-deterrent system would require setup and routine maintenance, including calibration 

19 of the radar to site-specific conditions to avoid false activations. The potential for other wildlife 

20 to access the surface impoundments would be minimized by the installation of fencing around 

21 the CPP and surface impoundments. Additionally, BMPs would be the same as those used by 

22 the Applicant during construction; therefore, the potential impacts of the Proposed Action’s 

23 operation would be SMALL for these birds.

24

25 Reptiles, Amphibians, and Aquatic Species 

26

27 The potential impact to reptiles and amphibians from the Proposed Action’s operation would be 

28 comparable to that described earlier for its construction. Because the potential habitat for 

29 reptiles and amphibians is limited within the Ross Project area, the potential impacts would be 

30 limited and SMALL. Because of the limited occurrence of surface water and, thus, of aquatic 

31 species at the Project area, the potential impact to aquatic species would be SMALL.

32

33 Protected Species

34

35 No impacts to Federally-listed threatened and endangered species would occur during the 

36 operation phase because these species have not been identified at the Ross Project area. 

37 Potential impacts to the protected species during the Project’s operation would be the same or 

38 less than those discussed above for the construction of the Ross Project because there would 

39 be fewer humans present outdoors on the site itself and fewer vehicles being used. In general, 

40 outdoor activities would be limited. Thus, the impacts would be SMALL to all protected species. 

41 In addition, mitigation measures implemented during the Project’s construction would continue 

42 to be employed to ensure that potential impacts to protected species remain SMALL. 

43

44 As noted in SEIS Section 4.6.1.1, specific mitigation measures for all ecological resources 

45 would be required by several Federal and State agencies; these measures would be 

46 implemented during the Proposed Action’s operation. These include the Applicant reseeding 

47 disturbed areas with WDEQ- and County-approved seed mixtures to prevent the establishment 

48 of competitive weeds and monitoring of invasive and noxious weeds. If these weeds become 

49 an issue, then the Applicant would employ other control alternatives, such as the application of 
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1 herbicides, to minimize their impacts. In addition, impacts to vegetation and wildlife resulting 

2 from spills and leaks would be mitigated by the Applicant’s use of BMPs. BMPs would include 

3 several leak-detection systems and spill-response plans, where released solutions would be 

4 contained and affected soils would be removed, thereby reducing the impacts of such releases.

5

6 All impacts of the Proposed Action’s operation would be SMALL to the ecology of the area.

7

8 4.6.1.3 Ross Project Aquifer Restoration 

9

10 In GEIS Section 4.4.5, the potential impacts to ecological resources during the aquifer11 restoration phase of an ISR facility are described (NRC, 2009). These impacts were noted to 

12 include habitat disruption. As noted above, however, in the case of the Ross Project, the 

13 already in-place infrastructure from the construction and operation phases (i.e., roads) would 

14 continue to be used, and little additional ground disturbance would be expected. 

15

16 Contamination of soils and surface waters could result from spills and leaks, which could impact 

17 the ecological resources of the Ross Project. The leak-detection systems and spill-response 

18 protocols described earlier, and the eventual radiation survey of all potentially impacted soils 

19 and sediments, would limit the magnitude of overall impacts to terrestrial and aquatic ecology 

20 during the aquifer restoration at the Proposed Action. In addition, continued implementation of 

21 mitigation measures, such as perimeter fencing and the avian-deterrent system would ensure 

22 that impacts to vegetation and terrestrial species would be minimized during aquifer restoration 

23 at the Ross Project. Also, because the existing infrastructure would be in place, the potential 

24 impacts to ecological resources from aquifer-restoration activities would be similar or less than 

25 that experienced during the Proposed Action’s operation phase, wildlife would have already 

26 retreated or learned to tolerate the presence of humans or noise. Therefore, the potential 

27 impacts to vegetation and wildlife would be SMALL. 

28

29 There would be no expected impacts to protected species during aquifer restoration beyond 

30 those which occurred during the construction and operation phases of the Proposed Action, 

31 because the existing infrastructure would be in place and no further excavation of habitat would 

32 be necessary. Additionally, to date, no threatened or endangered species have been observed 

33 at the Ross Project area. Therefore, the overall impact to threatened, endangered, or protected 

34 species during aquifer restoration would be SMALL. 

35 4.6.1.4 Ross Project Decommissioning

36

37 As discussed in GEIS Section 4.4.1, temporary land disturbance during the decommissioning of 

38 ISR facilities would be a result of excavation and disturbance of soils; excavation and removal of 

39 buried pipelines; and the decontamination, dismantling, demolition, and removal of buildings 

40 and structures (NRC, 2009). However, any recontouring of land and its revegetation would 

41 assist in the restoration of habitats previously altered during an ISR facility’s construction and 

42 operation. Wildlife would be temporarily displaced during the decommissioning phase, but 

43 species could return upon completion of this phase, when the restoration of vegetation and 

44 habitat has been accomplished. Although facility decommissioning and site restoration would 

45 result in temporary increases in sediment load in local streams, aquatic species would recover 

46 quickly as the additional sediment load decreased. For all of these reasons, the GEIS 

47 concluded the overall potential impact during the decommissioning of an ISR facility would be 

48 SMALL.
DRAFT Environmental Impacts and Mitigation Measures

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1 The Proposed Action’s decommissioning would be phased over approximately the last five 

2 years of the Ross Project. The Applicant estimates a 12-month duration for the 

3 decommissioning of the CPP, surface impoundments, pipelines, roads, and other infrastructure 

4 (if the CPP does not continue to operate for satellite and/or other offsite uranium-loaded IX-resin 

5 processing). Stockpiled topsoil would be used to regrade the land to its pre-licensing baseline 

6 contours, as required, and be reseeded with native vegetation when the buildings and structures 

7 are removed as described earlier (see SEIS Section 2.1.1). No loss of vegetative communities 

8 beyond that disturbed during the construction phase would occur. Pipeline removal would 

9 impact vegetation that could have re-established itself, although this, too, would be temporary 

10 as the disturbed areas are reseeded. Thus, the impacts of the Proposed Action’s 

11 decommissioning would not be expected to be greater than those experienced during its 

12 construction, and mitigation measures would continue to be employed. Consequently, the 

13 decommissioning impacts to vegetation would be SMALL. 

14

15 The decommissioning of the Proposed Action would create increased noise and traffic as 

16 buildings and structures are decontaminated, dismantled, demolished, and transported offsite to 

17 an appropriate waste-disposal facility. During this time, wildlife could either come in conflict with 

18 heavy equipment or be disrupted by the higher-than-normal noise. As a result of these impacts, 

19 wildlife would move elsewhere either on the Ross Project area or onto other lands. Temporarily 

20 displaced wildlife could return to the Ross Project area after the Proposed Action’s 

21 decommissioning and site restoration are complete. Further, as required by NRC regulations, 

22 the Applicant would be required to submit a decommissioning plan for Commission review and 

23 approval, which would address ecological impacts such as these. Thus, decommissioning 

24 impacts of the Ross Project would not be more than those experienced during the Proposed 

25 Action’s construction. Thus, the impacts to terrestrial wildlife, aquatic species, and protected 

26 species during decommissioning would be SMALL. 

27

28 4.6.2 Alternative 2: No Action

29

30 Under the No-Action Alternative, the Ross Project would not be licensed and the land would 

31 continue to be available for other uses. However, activities such as the plugging and proper 

32 abandonment of existing drillholes would occur as well as continued environmental monitoring, 

33 data collection, and field surveying. These activities, however, would be temporary in nature 

34 and the surface area affected would be very limited. 

35 The Ross Project area would continue to support vegetation communities and wildlife habitat 

36 typical of the region (as described in SEIS Section 3.). Land use would continue as 

37 pastureland, and existing grazing leases would continue. Grazing of existing vegetation, 

38 particularly in the grassland communities, would continue. Existing wildlife on the Ross Project 

39 area would be affected only if continued cattle grazing destroys wildlife habitat or if species are 

40 displaced by cattle populations because of lack of forage and cover. However, in this 

41 Alternative, only a few individual species would be affected, and they would relocate to suitable 

42 nearby habitats. Therefore, vegetation and wildlife impacts would be SMALL. 

43

44 4.6.3 Alternative 3: North Ross Project

45

46 Under Alternative 3, the North Ross Project would generally be the same as the Proposed 

47 Action, except that the facility (i.e., the CPP, associated buildings, and auxiliary structures as 

48 well as the surface impoundments) would be located to the north of where it would be located in 

49 the Proposed Action, as described in SEIS Section 2.1.3. The Applicant’s construction of the 
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1 CPP at this location would produce a slight increase in the travel distance for vehicles accessing 

2 the Ross Project’s facility and wellfields. This could slightly raise the potential for vehicular 

3 collisions with wildlife. However, the potential impacts during construction of Alternative 3 would 

4 be similar to those described for the Proposed Action. In addition, the surface impoundments 

5 would be located farther away from the Oshoto Reservoir, which would reduce the likelihood of 

6 waterfowl and other wildlife entering the surface impoundments. This would reduce the impacts 

7 to wildlife during the operation and aquifer-restoration phases of Alternative 3. All other impacts 

8 would be the same as for the Proposed Action, and the same mitigation measures would be 

9 implemented. The impacts of the North Ross Project would be of the same magnitude as

10 during the Proposed Action, and they would be SMALL.

11

12 4.7 Air Quality

13

14 The Proposed Action could impact air quality during all phases of the Project’s lifecycle. As 

15 discussed in GEIS Section 3.4.6 and in SEIS Section 3.7.1, Wyoming is generally a very windy 

16 state and ranks first in the U.S. with an annual average wind speed of 6 m/s [13 mi/hr]. During 

17 winter, wind speeds in Wyoming can reach 13 – 18 m/s [30 – 40 mi/hr] with gusts to 22 – 27 m/s 

18 [50 – 60 mi/hr] (NRC, 2009). During the 12 months of pre-licensing baseline monitoring at the 

19 Ross Project area, the onsite meteorology station recorded average annual wind speeds of 19 

20 km/hr [12 mi/hr], with a maximum wind speed of 74 km/hr [46 mi/hr]. Southerly winds were 

21 predominantly recorded at the Ross Project area. These data suggest that combustion-engine 

22 and fugitive-dust emissions from the Ross Project would be moved by the highest wind speeds 

23 to the south-southeast, away from the Project area. 

24

25 In addition to the winds, the Ross Project area and the surrounding region receive relatively little 

26 rainfall, with average annual precipitation ranging from 25 – 38 cm [10 – 15 in]. The region 

27 receives an average annual snowfall of 127 – 152 cm [50 – 60 in]; approximately one-half of the 

28 precipitation is associated with spring snows and thunderstorms. At the Ross Project 

29 meteorological station, the total precipitation measured in 2010 was 24.8 cm [9.8 in] (Strata, 

30 2011a). 

31

32 Because the Ross Project area is very dry and very windy, fugitive dust is readily generated and 

33 is a significant air pollutant (i.e., unwanted chemical vapor, gaseous, or particulate emissions 

34 found in the air, especially in disturbed land areas and areas where native vegetation has been 

35 removed). Conversely, these high winds could also more rapidly disperse air pollutants, 

36 lowering their concentrations. But the arid conditions in the Ross Project area are not as 

37 conducive to removal of suspended dust as areas receiving more rainfall. Therefore, in general, 

38 other mechanisms besides precipitation would need to be implemented within the Ross Project 

39 area to minimize fugitive dusts and other air emissions. 

40

41 Air pollutants can also be affected by the regional landscape of an area. The Ross Project’s 

42 topographical setting—an area consisting of rolling hills and intermittent drainages—provides 

43 some topographic breaks (see SEIS Section 2.1.1) (Strata, 2011a). In addition, the nearest 

44 mountain range is the Black Hills, whose westernmost edge is approximately 32 km [20 mi] from 

45 the eastern boundary of the Ross Project area. It has been suggested that this range may 

46 shield easterly winds and channel predominant winds into a north-south pattern (Strata, 2011a). 

47

48 Finally, atmospheric-stability classification and mixing height are environmental variables that 

49 also influence the ability of the atmosphere to disperse air pollutants. The “stability class” is a 
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1 measure of atmospheric turbulence and “mixing height” characterizes the vertical extent of 

2 contaminant mixing in the atmosphere. Stability-class information was collected at the Ross 

3 Project meteorological station (Strata, 2011a) and indicated that the class distributions were 

4 predominantly neutral (approximately 62 percent of the time). 

5

6 This background information indicates that potential impacts to air quality could occur during all 

7 phases of the Ross Project, and the impacts could be related to both the particulate emissions 

8 (e.g., fugitive dust) as well as gaseous emissions (or effluents) (e.g., combustion-engine 

9 emissions) that would be released during the Ross Project. Consistent with the GEIS, the air 

10 quality impacts analyzed in Section 4.7 only cover nonradiological emissions. Radiological 

11 emissions and dose information are addressed in the public and occupational health and safety 

12 impacts analyses in Section 4.13.

13

14 4.7.1 Alternative 1: Proposed Action

15

16 Alternative 1, the Proposed Action, consists of four phases: construction, operation, aquifer 

17 restoration, and decommissioning of a uranium-recovery facility and wellfields. The GEIS in 

18 Section 4.2.6 as cited in GEIS Section 4.4.6 determined that uranium-recovery facilities are not, 

19 in general, major air-emission sources (NRC, 2009). Given the low levels of particulate and 

20 gaseous emissions predicted in GEIS Section 4.2.6, the GEIS determined that the overall 

21 potential air-quality impacts of an ISR facility are SMALL, if the following three conditions could 

22 be applied to a specific facility: 1) particulate and gaseous emissions are within regulatory limits 

23 and requirements; 2) air quality in the [region] is in compliance with the National Ambient Air 

24 Quality Standards (NAAQS); and, 3) the facility would not be classified as a major source under 

25 the New Source Review or operating (Title V) air-quality permit programs which were described 

26 in the GEIS (NRC, 2009). As noted in GEIS Section 4.4.6, the entire NSDWUMR is an 

27 attainment area for NAAQS (see SEIS Section 3.7.3). 

28

29 These three conditions do describe the proposed Ross Project area. The Ross Project would 

30 be designed to ensure that its emissions are within regulatory limits and requirements; it would 

31 be located in the NSDWUMR which, as described in SEIS Section 3.7.3, is an attainment area 

32 for all NAAQS primary pollutants (i.e., is in compliance with NAAQS) (see Table 3.17 in SEIS 

33 Section 3.7.3); and, the Ross Project would not be classified as a major air-emissions source 

34 under New Source Review or Title V of the CAA. The Ross Project also would not impact the 

35 nearest prevention of significant deterioration (PSD) Class I areas. These conditions would 

36 apply to all phases of the Ross Project.

37

38 4.7.1.1 Ross Project Construction

39

40 Generation of fugitive dust during land-disturbing activities conducted during ISR facility 

41 construction would be the same as discussed in GEIS Section 4.3.6.1, and would be short-term. 

42 Other air-quality impacts from fugitive dust would result from road dust being suspended by 

43 moving vehicles over nearby and Ross Project roads as well as from construction equipment 

44 while it is used to clear and grade portions of the Project area where construction would occur. 

45 During the Proposed Action’s construction phase, the Applicant estimated a disturbance area of 

46 113 ha [280 ac] during construction of Ross Project buildings and auxiliary structures, surface 

47 impoundments, access roads, and other infrastructure. Traffic associated with the Ross Project 

48 would use the primary access route of New Haven Road or D Road, which are paved, such that 
DRAFT Environmental Impacts and Mitigation Measures

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1 impacts, including fugitive dust generation, would be limited to more occasional access on local 

2 dirt roads within the Ross Project area. 

3

4 Fugitive dust and other particulate emissions are regulated under the Wyoming Air Quality 

5 Standards and Regulations (WAQSR), Chapter 3, Section 2(f), “Fugitive Dust.” The WAQSR 

6 quantifies opacity and emission-specific constituent concentrations that apply exclusively to any 

7 point sources at the Ross Project (e.g., combustion engines) (WDEQ/AQD, 2011). In contrast 

8 to point sources, WDEQ/Air Quality Division (AQD) also regulates generalized fugitive-dust 

9 emissions by imposing BMPs rather than numerical limits. 

10

11 In a study of air-quality impacts of road construction, Roberts et al. (2010) found that near-road 

12 pollutant concentrations decline substantially within 100 – 150 m [330 – 490 ft] of the road, and 

13 they can reach background conditions at approximately 300 – 500 m [980 – 1,600 ft] from the 

14 road (Roberts, 2010). Similarly, a study by Countess et al., undertaken to improve the modeling 

15 of windblown and mechanically re-suspended fugitive-dust emissions, found that not all particles 

16 that could be suspended are in fact transported long distances; this is due to deposition rates, 

17 vertical mixing, and transport times. Countess found that PM10 (less than 10 μm in diameter) 

18 particulates (i.e., dusts) deposit relatively quickly at a rate of 0.5 – 5 cm/s [0.2 – 2 in/s]; PM2.5

19 particulates deposit more slowly at 0.05 – 0.2 cm/s [0.02 – 0.08 in/s], with a continuum of values 

20 between these two extremes for cropland, prairie land, and paved surfaces. In general, the 

21 fraction of the mechanically generated fugitive dust from roads and bare surfaces that is 

22 removed from the atmosphere by gravitational settling and by impacting nearby obstacles (such 

23 as vegetation) is much larger than that associated with fugitive windblown dust. This is because 

24 of the fact that the mechanically-generated particulates tend to remain closer to the ground for 

25 longer periods after suspension in the air than windblown dusts, such that there is a higher 

26 probability that these mechanically generated particles, such as those generated by vehicles, 

27 are removed from the atmosphere close to their sources. 

28

29 Windblown fugitive-dust emissions can be lofted vertically to great heights above the ground by 

30 the sustained energy provided by the vertical component of the wind, especially for strong 

31 winds, and consequently, can be transported much longer distances from their sources than 

32 mechanically generated fugitive-dust emissions. A typical wind speed of 2.5 m/s [8 ft/s] results 

33 in the transport of particulates to 100 m [330 ft] in 40 seconds, 1,000 m [3,300 ft] in 400 seconds 

34 (or approximately 7 min), and 10,000 m [33,000 ft] in 4,000 seconds [1.1 hr]. In general, PM10

35 particulates are deposited at a rate that is about an order of magnitude greater than PM2.5

36 because of the greater gravitational settling velocity (Countess, 2001). These data indicate that 

37 the majority of fugitive-dust impacts would not extend beyond the 80-km [50-mi] radius around 

38 the Ross Project area, although winds with large vertical components can transport dust over 

39 longer distances when they occur. This physical phenomenon is a de facto mitigation measure

40

41 The greatest combustion-engine gaseous emissions from diesel- and gas-powered equipment 

42 operation would occur primarily during the construction and decommissioning phases of the 

43 Ross Project because of the equipment used during those phases. To determine the potential 

44 air-quality impacts from the passenger vehicles of the commuting workforce as well as delivery 

45 and shipment trucks to and from the Ross Project area, the Applicant provided the anticipated 

46 number of passenger vehicle trips to and from the Ross Project during each of the Ross 

47 Project’s phases (see Table 4.2) (Strata, 2011a; Strata, 2012a). The Applicant also estimated 

48 the number of each type of supply, product, and waste shipment during each phase. Finally, 
DRAFT Environmental Impacts and Mitigation Measures

4-59

1 the Applicant estimated the annual operating time of these vehicles and other construction 

2 equipment (Strata, 2011a). 

3

4 All of this information is important when modeling air-quality impacts, as the Applicant did for 

5 each phase of the Proposed Action. In its air-quality modeling results, the Applicant provides 

6 (primarily diesel) combustion-engine emission and fugitive-dust estimates. These modeled 

7 emissions are provided in Table 4.4 for each phase of the Ross Project (Strata, 2011c; Strata, 

8 2011a). In the NRC’s evaluation, the assumptions used by the Applicant in its air-quality 

9 modeling efforts were conservative (e.g., each worker was assumed to commute to and from 

10 the Ross Project area alone). All emission levels were estimated to be below the major-source 

11 threshold for NAAQS attainment areas.

12

13 In order to determine impacts to air quality from diesel combustion emissions, the GEIS (NRC, 

14 2009) reported emissions for the ISR facility in Crownpoint, New Mexico, as described in the 

15 NRC’s Environmental Impact Statement (EIS) for that facility (NRC, 1997). Therefore, 

16 emissions from the Crownpoint ISR facility were examined for relevance to the Ross Project. 

17 Estimated maximum production of the Ross Project and Crownpoint are both 3 million pounds 

18 per year. The estimated gaseous particulate and gaseous emissions were presented in the 

19 Crownpoint EIS and in Table 2.72 of the GEIS. The results of the Crownpoint preliminary 

20 emissions inventory were similar to the Ross Project, with the exception of particulate matter 

21 (PM). PM emissions associated with the Crownpoint facility were approximately 10 T/yr, while 

22 combustion and fugitive PM emissions for the Ross Project were estimated at 177 T/yr. In 

23 addition, estimated combustion emissions for the Ross Project were significantly higher than 

24 those presented in the Crownpoint EIS. The differences can be attributed to the source of 

25 emissions factors (AP-42 emission factors were used in the Ross Project, which are significantly 

26 more conservative than the assumptions used for the Crownpoint analysis) as well as the 

27 estimated operating hours associated with each piece of equipment. The depth to ore deposits 

28 is greater at the Ross Project site than at Crownpoint, which would require that the equipment to 

29 reach the ore at the Ross Project would be operated for longer time periods and thus create 

30 more emissions.
DRAFT Environmental Impacts and Mitigation Measures

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Table 4.4

Non-Radioactive Emissions Summary

Construction Equipment and Truck Tailpipe Emissions

(t/yr [T/yr])

Phase TOC NOX CO PM10 SO2 CO2

Construction 13.27

[12.04]

181.77

[164.90]

39.50

[35.83]

11.89

[35.83]

10.83

[8.82]

7,014.9

[6,363.8]

Operation 3.09

[2.80]

38.78

[35.18]

8.36

[7.53]

2.75

[2.49]

2.56

[2.32]

1,438.6

[1,303.3]

Aquifer Restoration 1.8

[1.63]

22.7

[20.6]

4.9

[4.5]

1.61

[1.46]

1.50

[1.36]

842.6

[764.4]

Decommissioning 5.1

[4.63]

64.3

[58.3]

13.9

[12.6]

4.56

[4.14]

4.25

[3.86]

2,385.0

[2,163.6]

Fugitive-Dust PM10 Emissions

(t/yr and T/yr)

Phase Activity

PM10

(t/yr)

PM10

(T/yr)

Construction Equipment Site preparation for facility 10.60 11.69

Construction Equipment Wellfield and roads preparation 15.86 17.48

Construction Vehicles on unpaved roads 129.40 142.64

Construction Wind erosion from exposed areas 11.25 12.40

Operation Vehicles on unpaved roads 13.23 14.29

Operation Wind erosion from exposed areas 1.03 1.14

Operation Year five of ISR operation 5.69 6.27

Aquifer Restoration Vehicles on unpaved roads 8.89 9.80

Aquifer Restoration Wind erosion from exposed areas 1.03 1.14

Decommissioning Site preparation for CPP 2.01 2.21

Decommissioning Wellfield and roads preparation 4.64 5.12

Decommissioning Vehicles on unpaved roads 70.52 77.73

Decommissioning Wind erosion from exposed areas 5.79 6.38

Storage Tank Emissions Totals 

(kg/yr and lb/yr)

Hydrochloric Acid 42.92 47.31

Hydrogen Peroxide 0.98 1.08

Diesel 10.80 11.90

Gasoline 1,176.99 1,297.41

1 Source: Strata, 2011a; Strata, 2011b.

2 Note: t = Tonnes, or Metric tons.

3 T = Short tons, or U.S. tons.
DRAFT Environmental Impacts and Mitigation Measures

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1 The annual average particulate concentration at Crownpoint was estimated to be less than 2 

2 percent of the Federal PM2.5 ambient-air standard, less than 1 percent of the previous Federal 

3 and current Wyoming PM10 ambient-air standards, and less than 2 percent of the Class II PSD 

4 allowable increment. However, this estimate for annual average particulate concentration did 

5 not categorize the particulates as PM10 or PM2.5. The annual average SO2 concentration was 

6 estimated in the Crownpoint analysis to be less than 1 percent of both the Federal and the 

7 Wyoming ambient-air standards and less than 1 percent of the Class II PSD allowable 

8 increment. Finally, the annual average NO2 concentration at Crownpoint was estimated to be 

9 slightly over 2 percent of the Federal and Wyoming ambient-air standards, but less than 9 

10 percent of the Class II PSD allowable increment. Therefore, although PM emissions at the 

11 Ross Project could exceed those at Crownpoint, the low percentages of the ambient air quality 

12 standards estimated for the Crownpoint facility emissions indicate that the Ross Project 

13 emissions would also be below NAAQS and PSD standards.

14 Additionally, the meteorology used at the Crownpoint site to estimate average annual air 

15 concentrations of emitted pollutants is more stable than at the proposed Ross Project site, 

16 based on review of wind stability classes. At Crownpoint, winds that fall into stability classes E 

17 and F occur over twice as frequently as winds in stability classes E and F at the Ross Project 

18 site. Good dispersion conditions (stability classes A through D) occur approximately 80 percent 

19 of the time at the Ross Project site versus approximately 55 percent of the time at the 

20 Crownpoint site. Based on the information reviewed, the dispersion conditions at the Ross 

21 Project site are more favorable than at Crownpoint and would therefore help to reduce the 

22 impacts due to PM emissions. 

23

24 The Applicant proposes several onsite best available control technology (BACT) mitigation 

25 measures as well as many BMPs to control fugitive dust (e.g., fugitive dust would be minimized 

26 by the Applicant’s wetting soils down during earth-disturbing activities). The Applicant’s 

27 mitigation of fugitive dust from roads would also include setting appropriate speed limits for 

28 vehicle traffic, strategically placing water load-out facilities near access roads, using chemical 

29 dust suppressants (e.g., magnesium chloride), encouraging employee carpooling, and selecting 

30 road surfaces that would minimize fugitive dust. The placement of soil stockpiles on the 

31 leeward side of hills and the Applicant’s prompt revegetation of disturbed areas would also 

32 reduce the potential for fugitive dust. 

33

34 In addition, mitigation of all types of impacts to air quality, actual particulate- and gaseous35 emission concentrations from the Ross Project area, would be required to be monitored and to 

36 comply with the conditions of the WDEQ-issued Construction Air Quality Permit No. CT-12198 

37 (WDEQ/AQD, 2011). The gaseous-emission controls that the Applicant must employ during the 

38 Ross Project are outlined in its Air Quality Permit Application, which becomes part of the Air 

39 Quality Permit itself (Strata, 2011c). As specified, gaseous emissions would be controlled by 

40 the BACT for critical air-emission sources, such as acid-fume scrubbers on acid storage tanks 

41 (Strata, 2011c). Other BACTs are listed in the regulations implementing the CAA (40 CFR 

42 Subpart C). 

43

44 The Applicant also plans to use visual observation on at least an hourly basis to monitor air 

45 quality in the Ross Project area and on a twice-daily basis at locations along the primary access 

46 route leading to the Ross Project. Further, to ensure compliance, the WDEQ/AQD would 

47 conduct regular inspections as well as unannounced inspections of permitted facilities (Strata, 
DRAFT Environmental Impacts and Mitigation Measures

4-62

1 2012a). Finally, the Applicant would respond aggressively to any dust-related concerns 

2 expressed by its employees, contractors, or members of the public (Strata, 2012a). 

3 Given the predominant winds (in terms of both speed and direction) in the region, the remote 

4 location of the Ross Project area, and the BACT controls and BMPs that the Applicant is 

5 required by its Air Quality Permit to implement, many of the air emissions impacts from the 

6 Proposed Action would be fully mitigated (WDEQ/AQD, 2011). Because construction at the 

7 Ross Project would be typical of ISR facilities considered in the GEIS, anticipated gaseous8 emission and fugitive-dust impacts would be limited in duration during the construction phase, 

9 and they would be mitigated. Therefore, the impacts of the Proposed Action on air quality 

10 during the construction phase would be short-term and SMALL. 

11

12 4.7.1.2 Ross Project Operation

13

14 Air-quality impacts during the Ross Project’s operation phase could include the same as those 

15 identified earlier for the construction phase of the Proposed Action (i.e., fugitive-dust and 

16 gaseous combustion-engine emissions), and they would be generated by many of the same 

17 sources. Estimates for these sources are provided by project phase in the Applicant’s Air 

18 Quality Permit Application and are summarized here in Table 4.4 (Strata, 2011c). 

19

20 Impacts from fugitive-dust and gaseous combustion-engine emissions during the operation 

21 phase would be less than the construction phase impacts, however, because fewer vehicles 

22 would be in use on or near the Ross Project area. Worker commutes would be approximately 

23 60 workers during the operation phase (less than the 200 during construction). Construction24 equipment operation (where most portions of the Ross Project area would have been cleared 

25 and graded during construction, so little earth movement would occur during operation—only 

26 the installation of wellfields would continue to generate fugitive dust) would diminish 

27 substantially, thus generating less fugitive dust and gaseous emissions.

28

29 Several point sources could release emissions while the Ross Project is in its operation phase. 

30 These point sources of gaseous emissions would be located at the CPP. These would include 

31 process-pipeline, process-vessel, and storage-tank vents; emergency generators and space 

32 heaters; and other sources such as storage vessels and tanks containing acids and bases 

33 (Strata, 2011a). Gaseous emissions from the yellowcake dryer are not expected because of the 

34 design of the proposed Ross Project’s yellowcake circuit, which would include the BACT design 

35 of an indirect heat source as well as an integrated filter and condenser.

36

37 Gaseous emissions could also be released during the venting of excess vapor pressure from 

38 pipelines within the CPP, with small amounts of chemical vapor released. According to GEIS 

39 Section 4.4.6, excess vapor pressure in pipelines could be vented at various relief valves 

40 throughout the system. These emissions would be rapidly dispersed into the atmosphere, 

41 resulting in SMALL impacts (NRC, 2009). In addition, there could also be gaseous emissions 

42 during resin transfers or during resin elution (e.g., liquefied oxygen or carbon dioxide that come 

43 out of solution). The GEIS determined that a low volume of gaseous emissions would be 

44 released during resin transfer and elution at an ISR facility. 

45

46 The Applicant’s refilling of acid, sodium carbonate, or bicarbonate tanks would produce only 

47 small quantities of emissions; nonetheless, during the process of refilling the acid storage tanks, 

48 the BACT standard of a closed-loop system, which routes displaced vapors back to the tank 

49 truck during transfer, would be used (Strata, 2011c). The tanks would be located away from 
DRAFT Environmental Impacts and Mitigation Measures

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1 other chemical-storage tanks and away from the process vessels at the chemical-storage area 

2 (Strata, 2011b). Any emissions would be scrubbed for acid vapors prior to release to the 

3 atmosphere. Sodium carbonate and sodium bicarbonate would be delivered dry by truck and 

4 be blown into a storage silo; the vent of this silo would be filtered with a dust-vent bag to capture 

5 particulate emissions (Strata, 2011). The emissions from other storage vessels and tanks are 

6 summarized by the Applicant in its license application and additional information it has provided 

7 the NRC (Strata, 2011a; Strata, 2011b; Strata, 2012a) as well as in its Air Quality Permit 

8 Application (Strata, 2011c). 

9

10 An emergency generator would be required to supply power to critical process equipment in the 

11 event of a power failure. The Applicant’s Air Quality Permit restricts the generator’s operation to 

12 500 hours per year (WDEQ/AQD, 2011). Strata’s Air Quality Permit Application provides a 

13 summary of generator emissions. Emissions from the vacuum dryers and space heaters in the 

14 CPP (natural-gas-burning equipment) are also listed in the emissions inventory (Strata, 2011c). 

15 Table 4.4 summarizes the Applicant’s estimates of gaseous and particulate emissions, including 

16 from the point sources above, as they were modeled for the Air Quality Permit Application 

17 (Strata, 2011c). 

18

19 Other types of air-quality-impact mitigation measures include gaseous-emission control systems 

20 that minimize emissions, BMPs that have demonstrated success at controlling emissions, and 

21 BACT engineering controls that reduce airborne emissions as well as minimize the potential for 

22 accidental releases. For example, powdered-form chemicals that would be delivered to the 

23 Ross Project would be delivered in covered trucks and unloaded through sealed pathways into 

24 tanks vented through dust-vent bags or fabric filters. Earth-moving and excavation activities 

25 would be governed by BMPs to minimize fugitive dust from disturbed areas, such as the 

26 Applicant watering dry soils thoroughly during such activities. To ensure that all requirements of 

27 the Air Quality Permit are being met, WDEQ/AQD would conduct regular inspections and 

28 unannounced visits of the Proposed Action (Strata, 2012a). 

29

30 During operations, the Applicant will be required to monitor the effluent and selected 

31 environmental media to establish the impacts. Thus, the air-quality impacts of the Proposed 

32 Action during the operation phase would be SMALL.

33

34 4.7.1.3 Ross Project Aquifer Restoration

35

36 According to GEIS Section 4.4.6, potential nonradiological air-quality impacts during the aquifer37 restoration phase of an ISR facility would include combustion-engine and fugitive-dust 

38 emissions from many of the same sources identified during the construction and operation 

39 phases. These impacts were found to be SMALL. 

40

41 During the aquifer-restoration phase of the Proposed Action, the plugging and abandonment of 

42 injection and recovery wells would begin after a wellfield has undergone restoration and has met 

43 its ground-water quality goals. The emissions associated with the related equipment would be 

44 limited in duration and result in small, short-term effects. Vehicular traffic during the aquifer45 restoration phase would be limited to delivery of supplies and commuting personnel; however, 

46 the workforce at the Ross Project would decrease to 20 during aquifer restoration and, 

47 consequently, the vehicular emissions of commuting traffic would substantially decrease. A 

48 significant decrease in the frequency of offsite yellowcake shipments would also occur as 

49 aquifer restoration proceeds. Thus, the emission-generating activities during the aquifer-
DRAFT Environmental Impacts and Mitigation Measures

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1 restoration phase would be many fewer than during either the construction or operation phases. 

2 Therefore, air-quality impacts of aquifer restoration would be SMALL.

3

4 4.7.1.4 Ross Project Decommissioning

5

6 According to Section 4.4.6 of the GEIS, potential air-quality impacts during an ISR facility’s 

7 decommissioning phase include fugitive dust, vehicle emissions, and the combustion-engine 

8 emissions from many of the same sources identified for the earlier phases of the facility’s 

9 lifecycle (NRC, 2009). At the Ross Project, in the short term, emissions could increase, 

10 especially particulates, because decommissioning of the ISR facility would generate fugitive 

11 dust and the related construction equipment would also generate some gaseous emissions. 

12 The Applicant’s dismantling and demolition of Ross Project buildings, structures, surface 

13 impoundments, and process equipment; its excavation and removal of any contaminated soils; 

14 its relocation of construction equipment to the different areas where decommissioning activities 

15 would take place; and its grading and re-contouring of the site during reclamation and 

16 restoration would produce particulate matter that would impact air quality. Combustion-engine 

17 gaseous emissions would also be generated by not only construction vehicles, but also vehicles 

18 transporting workers to and from the Ross Project (an additional 70 workers would be employed 

19 at the Ross Project during its decommissioning phase) (Strata, 2011a). Truck traffic related to 

20 the shipment of demolition and other wastes would also increase during the decommissioning 

21 phase as the wastes are shipped to various disposal facilities. However, the truck traffic would 

22 be only approximately 40 percent of that during the construction phase. 

23

24 All of the respective mitigation measures identified for the other phases of the Proposed Action 

25 would continue to be implemented by the Applicant during decommissioning. Consequently, the 

26 overall decommissioning-phase impacts would be similar to or less than construction-phase 

27 impacts; therefore, decommissioning phase impacts would be SMALL.

28

29 4.7.2 Alternative 2: No Action

30

31 Under the No-Action Alternative, the Ross Project would not be licensed and the land would 

32 continue to be available for other uses. However, the Applicant could choose to continue with 

33 some preconstruction activities, such as its abandonment of exploration drillholes and its data 

34 collection and monitoring of the area. These activities would be similar to or of smaller scale as 

35 those activities currently occurring at the Ross Project area. These activities would require 

36 some equipment and vehicular access to the Ross Project area, which would result in small 

37 fugitive-dust and gaseous emissions. Other potential sources of air-quality impacts in the region 

38 (including oil-production activities) would continue as well, where emission releases from oil39 recovery activities within the area could result from accidental pipe breaks or equipment and 

40 infrastructure-system failures. All of these potential emissions would be limited and short term. 

41 Thus, the air-quality impacts would be SMALL for the No-action Alternative.

42

43 4.7.3 Alternative 3: North Ross Project

44

45 Under Alternative 3, the North Ross Project would generally be the same as the Proposed 

46 Action, except that the facility (i.e., the CPP, associated buildings, and auxiliary structures as 

47 well as the surface impoundments) would be located to the north of where it would be located in 

48 the Proposed Action, as described in SEIS Section 2.1.3. At the north location, a CBW would 

49 not be required. Therefore, the incremental contribution to air quality impacts that would result 
DRAFT Environmental Impacts and Mitigation Measures

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1 from the construction and partial removal of the CBW would not occur under Alternative 3. 

2 However, additional construction activities in Alternative 3, such as greater land disturbance due 

3 to surface-impoundment construction due to the north site’s topography, would be somewhat 

4 greater than those in the Proposed Action. The air quality impacts associated with these 

5 activities are not significant relative to the air quality impacts that would occur due to the 

6 activities that these two alternatives have in common. Therefore, the air-quality impacts of 

7 Alternative 3 would be expected to be similar to the air-quality impacts of the Proposed Action. 

8 Thus, the air-quality impacts of Alternative 3 would be SMALL.

9

10 4.8 Noise 

11

12 The Proposed Action will generate noise during all phases of the Project’s lifecycle. As noted in

13 GEIS Section 3.3.1, most ISR facilities are proposed for undeveloped rural areas at least 16 km 

14 [10 mi] from the nearest communities. However, as described in SEIS Section 3.2, there are

15 eleven residences within the surrounding 3 km [2 mi] radius of the proposed Ross Project. Four 

16 of these residences are located within 300 m [1,000 ft] of the Ross Project’s boundary. The 

17 GEIS indicates that 300 m [1,000 ft] is the distance outside of which noise from construction 

18 activities will return to background. The nearest two residences of the four within 300 m [1,000 

19 ft] of the Project are 210 m [690 ft] and 250 m [835 ft] from the Project’s boundaries and 800 m 

20 [2,500 ft] and 1,700 m [5,600 ft] from the proposed location of the CPP and surface 

21 impoundments (i.e., the facility) (see SEIS Figure 3.3). There are no sensitive areas, such as 

22 schools, churches, synagogues, or mosques or community centers, located less than 300 m 

23 [1,000 ft] from the Ross Project’s boundaries (Strata, 2011a). There are no residences within

24 the Project area itself. 

25

26 As described in SEIS Section 3.3, the primary access routes to or from the Ross Project area 

27 would be from I-90 north on either D or New Haven Roads (Strata, 2011a). As noted in SEIS 

28 Section 3.8, both of the two nearest residences to the Ross Project are located along New 

29 Haven Road. Truck traffic, in particular bentonite hauling from the Oshoto bentonite mine 5 km 

30 [3 mi] north of the Ross Project area and, less frequently, livestock hauling, are the main 

31 contributors to existing traffic noise on D and New Haven Roads. Two noise studies were 

32 conducted by the Applicant to establish the baseline noise levels in and around the Ross Project 

33 area (see SEIS Section 3.8). One study measured baseline noise with a sound-level meter at 

34 two of four nearby residences (i.e., the nearest offsite “receptors”). Pre-licensing baseline noise 

35 levels at these residences averaged between 35.4 and 37.4 dBA, depending upon simultaneous 

36 factors such as wind speed, traffic volume, vehicular speed, and the type of load being 

37 transported (Strata, 2011a). The Applicant’s second noise study collected baseline noise level 

38 data at its Field Office in Oshoto, 15 m [50 ft] away from New Haven Road and adjacent to the 

39 Ross Project area (see Figure 3.1 in SEIS Section 3.2). The latter study demonstrated that the 

40 average, daily duration of noise levels above 55 dBA at the Field Office was 62 minutes per day 

41 (Strata, 2011a). This noise was attributed to traffic, because of the Office’s close proximity to 

42 New Haven Road. The EPA identifies noise at or greater than 55 dBA, with a margin of safety 

43 determined to protect hearing, as causing outdoor activity interference and annoyance. The

44 EPA identifies noise at or greater than 45 dBA, with a margin of safety determined to protect 

45 hearing, as causing indoor activity interference and annoyance (EPA, 1978). 
DRAFT Environmental Impacts and Mitigation Measures

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1 4.8.1 Alternative 1: Proposed Action

2

3 Alternative 1, the Proposed Action, consists of four phases: construction, operation, aquifer 

4 restoration, and decommissioning of a uranium-recovery facility and wellfields. At the Ross 

5 Project, impacts from noise could be a result of vehicular traffic, such as those from commuter 

6 vehicles; deliveries of supplies, materials, and equipment; and shipments of yellowcake and 

7 wastes within and outside of the Ross Project area. In addition, equipment operation, such as 

8 trucks and other heavy pieces of construction equipment, as well as smaller equipment, such as 

9 pump jacks and compressors, and wellfield and CPP operation could be sources of noise. Both 

10 humans and wildlife are defined as potential receptors in the vicinity of the Ross Project area. 

11

12 4.8.1.1 Ross Project Construction

13

14 The GEIS (Section 4.4.7.1) stated that because of the use of heavy equipment (e.g. bulldozers, 

15 graders, drill rigs, compressors), potential noise impacts would be greatest when an ISR facility 

16 is being built (NRC, 2009). This section of the GEIS concluded that the noise impacts during 

17 construction would be SMALL to MODERATE, where facility construction and wellfield 

18 installation would be expected to have only SMALL and temporary noise impacts for residences

19 or communities that are located more than about 300 m [1,000 ft] from noise-generating 

20 activities. The MODERATE rating would be limited to temporary noise impacts to the very 

21 nearest residences traffic (NRC, 2009). 

22

23 Table 4.5 indicates the noise levels that have been calculated for the different types of 

24 construction equipment planned for use at the Proposed Action, at three different distances: 15 

25 m [50 ft], which would represent nearby workers; 210 m [690 ft], which would represent the 

26 residence nearest the Project’s boundary; and 762 m [2,500 ft], which would represent the 

27 residence nearest the Ross Project’s proposed CPP (Strata, 2011a). 28

Table 4.5

Respective Noise Levels of Construction Equipment

Equipment Type

Noise Levela

(15 m [50 ft])

(dBA)

Noise Levelb

(210 m [690 ft])

(dBA)

Noise Levelc

(762 m [2,500 ft])

(dBA)

Heavy Truck 82-96 59-73 24-38

Bulldozer 92-109 69-86 34-51

Grader 79-93 56-70 21-35

Excavator 81-97 58-74 23-39

Crane 74-89 51-66 16-31

Concrete Mixer 75-88 52-65 17-30

Compressor 73-88 50-65 15-30

Backhoe 72-90 49-67 14-32

Front Loader 72-90 49-67 14-32

Generator 71-82 48-59 13-24

Jackhammer/Rock Drill 75-99 52-76 17-41

Pump 68-80 45-57 10-22

Drill Rigd 52-74 29-51 18-40

29 Source: NRC, 2009b; Strata, 2011a.
DRAFT Environmental Impacts and Mitigation Measures

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1 Notes for Table 4.5:

2 a = Taken from the GEIS.

3 b = Minimum distance between the Ross Project’s boundary and nearest residence.

4 c = Minimum distance between the CPP and nearest residence.

5 d = Based upon Strata’s 2010 noise study.

6

7 Heavy equipment operation within the Ross Project area would peak during the Applicant’s 

8 construction of the CPP, surface impoundments, wellfields, and associated infrastructure. The 

9 majority of construction equipment would only be operated during daylight hours, and these 

10 activities would be more than 300 m [1,000 ft] from the nearest residences; thus, associated 

11 noise would not exceed the 24-hour average sound-energy guideline of 70 dBA or the daytime 

12 average of 55 dBA, the level EPA identifies as protective against interference of receptor 

13 activities and receptor annoyance, with a margin of safety determined to protect hearing (EPA, 

14 1978). The noise impacts to nearby residents due to heavy equipment operation would thus be 

15 SMALL. Impacts to workers during the Ross Project’s construction would be SMALL, because 

16 the Applicant would comply with Occupational Safety and Health Administration (OSHA)

17 regulations concerning noise. Further, a Hearing Conservation Program would be conducted by 

18 the Applicant, which would require assessment of noise exposures, provision of hearing 

19 protection when noise levels exceed the daily permissible exposure levels, performance of 

20 periodic audiograms, and stipulation of worker training regarding noise and hearing, all 

21 consistent with 29 CFR Part 1910.95.

22

23 Impulse or impact noises from certain equipment, such as impact wrenches and pneumatic 

24 attachments on rock breakers, could be particularly annoying to residents. These types of 

25 equipment could be present during some construction activities of the Proposed Action. 

26 However, the primary locations of these noises would be at least 335 m [1,100 ft] from the 

27 nearest residence, significantly reducing their perception by residents. The average noise at 

28 residences resulting from equipment-related impact or impulse noises would not be expected to 

29 reach the 55 dBA nuisance level (Strata, 2012a). Thus, the impacts of impulse noise would be 

30 SMALL.

31

32 Indoor noise levels due to outside activities typically range from15 to 25 dBA lower than outdoor 

33 levels, depending on whether windows are open or closed. With windows open during daytime 

34 hours, indoor noise levels could be have the potential to be greater than the average 55 dBA 

35 outdoor level that the EPA defines as preventing receptor activities, interfering with their lives, 

36 and annoying them, largely because of truck traffic (EPA, 1978). However, since distances 

37 would be greater than 300 m [1,000 ft] from ongoing construction activities, potential indoor 

38 noise impacts would be SMALL. 

39

40 Approximately 85 percent of the overall construction workforce would commute during the 

41 daytime (Strata, 2012a), where such commutes would occur to and from the Ross Project in 

42 single-occupant cars. Additional traffic would occur due to the relocation of construction 

43 equipment to and from the Ross Project area. Noise resulting from vehicle and truck traffic 

44 could occasionally be annoying to residents within 300 m [1,000 ft] of noise sources at the 

45 Proposed Action, particularly during nighttime hours. However, the Applicant estimates that 90 

46 – 95 percent of all deliveries of supplies, materials, process chemicals, and equipment would 

47 occur during daytime hours. Because the county roads to and from the Ross Project area 

48 currently have very low average daily and annual traffic counts, there would be a high relative 
DRAFT Environmental Impacts and Mitigation Measures

4-68

1 increase in vehicular traffic and, thus, noise impacts to nearby residents would be MODERATE; 

2 the more distant local communities would experience only SMALL, temporary impacts. 

3

4 Elevated noise levels associated with construction activities could also affect wildlife behavior 

5 onsite. For example, continuous elevated noise levels could reduce the breeding success of the 

6 Greater sage-grouse, if the birds were located near construction equipment, making it more 

7 difficult for the female sage-grouse hens to locate and respond to the vocalizations of the males. 

8 In general, however, wildlife would likely avoid the areas where noise-generating activities are 

9 ongoing (see SEIS Section 4.6). Thus, noise impacts to wildlife would be SMALL. 

10

11 To minimize noise impacts to all receptors, the Applicant proposes additional mitigation 

12 measures. For example, the USDOT reports that, for heavy trucks, speeds of 80 – 160 km/hr

13 [50 – 100 mi/hr] result in noise levels of 80 – 97 dBA, while noise levels of 62 – 74 dBA result 

14 when passenger vehicles travel within the same speed range (USDOT, 1995). On rough 

15 roads, noise levels would be higher. Therefore, the speed limits for onsite and local county 

16 roads are a component of the Applicant’s planned mitigation of noise impacts. Traffic-related 

17 noise impacts would be minimized by the Applicant’s working with Crook County to implement 

18 and enforce additional speed limits on the roads as well as to develop its own speed-limit policy 

19 for employees and contractors. Regular maintenance of all road surfaces to avoid ruts, 

20 potholes, and uneven wear patterns would also minimize noise impacts from vehicle and truck 

21 traffic. 

22

23 The presence of vegetation and topographic features between the noise-generating activity and 

24 the receptor would reduce noise levels even more (Countess, 2001). The large topographic 

25 features that exist in the Ross Project area (i.e., steep hills and ridges) between the noise26 generating construction activities and the nearest receptors would act as barriers to noise 

27 propagation. Mitigation measures that would be implemented by the Applicant would include 

28 nighttime drilling restrictions within a specified distance of residences, daylight-hour use of 

29 construction equipment, “first move forward” driving policies to limit backup alarms from trucks, 

30 and speed limit enforcement on access roads. The Applicant would also limit the use of 

31 equipment with loud engines, unrestricted exhaust systems, and compression brakes (Strata, 

32 2011a).

33

34 Thus, the noise impacts during the Proposed Action’s construction would be SMALL to 

35 MODERATE, where only the closest residents to the Ross Project would experience 

36 MODERATE, but short term, exposures to noise.

37

38 4.8.1.2 Ross Project Operation

39

40 As noted in GEIS Section 4.4.7, the noise impacts of an ISR facility during the operation phase 

41 would be SMALL to MODERATE (NRC, 2009). Truck traffic would be present during the 

42 Proposed Action’s operation phase and would be associated with yellowcake, vanadium, and 

43 waste shipments (16 trucks would be expected during operation vs. 24 during construction). 

44 Commuter-traffic noise would decrease because of the smaller workforce required during ISR 

45 operations (60 workers would commute per day during operation vs. 200 during construction). 

46 Thus, traffic noise impacts produced at the Ross Project during operation would be SMALL to 

47 MODERATE, but these would be short term and limited to the nearest receptors (i.e., 

48 residences). 
DRAFT Environmental Impacts and Mitigation Measures

4-69

1 During the operation phase, most of the Proposed Action’s uranium-recovery activities would be 

2 conducted inside buildings (although some wellfield activities would take place outdoors) and 

3 fewer pieces of heavy machinery would be used. Therefore, the potential noise impacts from 

4 the operation of equipment during the operation phase would be less than those discussed 

5 under the construction phase and would be SMALL. Noise emanating from the CPP from a 

6 variety of mechanical equipment (e.g. generators; pumps; air compressors; and heating, 

7 ventilation, and air conditioning systems) is not expected to exceed the 55 dBA nuisance level 

8 because the doors to the CPP would be kept closed as much as possible. Since noise levels 

9 decrease significantly with distance and because the CPP would be located approximately 760 

10 m [2,500 ft] from the Ross Project boundary, impacts due to noise emanating from the CPP are 

11 expected to be SMALL.

12

13 As during the construction phase, noise from the Ross Project’s operation would have SMALL 

14 impacts to wildlife, which would likely avoid areas where noise-generating activities are ongoing. 

15 Similarly, health and safety impacts to personnel at the Ross Project would be SMALL because 

16 most of the noise associated with construction would no longer take place. 

17

18 The specific mitigation measures related to noise impacts adopted by the Applicant during Ross 

19 Project construction would continue through its operation. Every plant worker would be 

20 periodically retrained to understand the hazards of excess noise and how to decrease noise 

21 impacts under the hearing conservation program the Applicant would develop. 

22

23 4.8.1.3 Ross Project Aquifer Restoration 

24

25 As noted in GEIS Section 4.4.7.1, the overall noise impacts during aquifer restoration would be 

26 SMALL to MODERATE (NRC, 2009). However, noise impacts during the aquifer-restoration 

27 phase at the Ross Project would be SMALL because truck traffic would subside to only 

28 approximately 12 shipments per day, because overall density of residences and receptors near 

29 the Ross Project area is sparse, and because the noise-mitigation measures that the Applicant

30 would undertake would minimize noise. All noise impacts would also be temporary. In addition, 

31 the workforce employed during aquifer restoration would be smaller (i.e., 20 workers) than that 

32 during the construction and operation phases of the Proposed Action and, thus, there would be 

33 fewer workers, less traffic, and fewer noise-producing activities. Finally, the Applicant’s 

34 continued compliance with OSHA noise standards would minimize noise impacts to workers. 

35 Wildlife would continue to avoid the areas where noise-generating activities are ongoing (e.g., 

36 the wellfields). All of these factors would ensure that the noise impacts during the aquifer37 restoration phase of the Proposed Action are SMALL.

38

39 4.8.1.4 Ross Project Decommissioning 

40

41 The GEIS indicated that noise impacts emanating from an ISR facility undergoing 

42 decommissioning would be SMALL to MODERATE. At the Ross Project, noise levels during the 

43 decommissioning phase of the Proposed Action would be similar to or less than those identified 

44 for the construction phase, for both onsite receptors (i.e., workers) and offsite receptors (i.e., 

45 nearest residents). Most potential impacts to nearby residences would occur as a result of the 

46 increased noise due to commuter and truck traffic to and from the Ross Project area during 

47 decommissioning (i.e., 90 workers and additional waste shipments) and would be SMALL to 

48 MODERATE. 
DRAFT Environmental Impacts and Mitigation Measures

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1 Many decommissioning activities would be focused at the ISR facility itself (i.e., the CPP, the 

2 surface impoundments, and auxiliary structures), where activities would include 

3 decontamination, dismantling, and demolition of these structures, which would be accomplished 

4 through the use of heavy equipment. However because this area is approximately 762 m [2,500 

5 ft] from the nearest residential receptor, noise impacts to the nearest residents would be 

6 SMALL. In the wellfields, equipment used during plugging and abandonment of recovery, 

7 injection, and monitoring wells, such as cement mixers, compressors, and pumps, would 

8 produce significant levels of short-term noise. Impacts to workers during the Proposed Action’s 

9 decommissioning would be SMALL, due to the same variables indicated earlier for its 

10 construction and operation as well as for aquifer restoration (i.e., OSHA noise-standard 

11 compliance). The same is true for wildlife noise receptors, which would avoid the locations 

12 where decommissioning activities are taking place.

13

14 Despite the standard mitigation measures taken during decommissioning—the same as those 

15 identified for the other phases of the Proposed Action—the distance from the closest residences 

16 to the Ross Project would cause the noise impacts to be SMALL to MODERATE, but short-term.

17

18 4.8.2 Alternative 2: No Action

19

20 Under the No-Action Alternative, the Ross Project would not be licensed and the land would 

21 continue to be available for other uses. However, the preconstruction activities the Applicant

22 has undertaken, such as the plugging and abandonment of wells, could continue under the No23 Action Alternative. Thus, the noise levels within the Ross Project area, where the measured 

24 baseline noise levels are 36 to 40 dBA, could continue (Strata, 2011a). This noise would 

25 occasionally be elevated by the passing of heavy trucks and passenger vehicles, nearby 

26 agricultural activities, and nearby oil-production activities (Strata, 2011a). Thus, the noise 

27 impacts of Alternative 2 would be SMALL.

28

29 4.8.3 Alternative 3: North Ross Project

30

31 Under Alternative 3, the North Ross Project would generally be the same as the Proposed 

32 Action, except that the facility (i.e., the CPP, associated buildings, and auxiliary structures as 

33 well as the surface impoundments) would be located to the north of where it would be located in 

34 the Proposed Action, as described in SEIS Section 2.1.3. However, because the north site of 

35 Alternative 3 is farther away from main roads than the south site of the Proposed Action, the 

36 north site’s nearest residential receptors are farther away than from the location of the south 

37 site. Therefore, the noise generated by construction equipment would be even less likely to 

38 exceed the 55 dBA nuisance level at the closest residences. Within the fenced facility area 

39 itself, the noise levels during construction of Alternative 3 would be similar to those in the 

40 Proposed Action because the same types of construction activities would take place. 

41

42 The noise levels associated with vehicle and truck traffic volume under Alternative 3 would be 

43 essentially the same as described for the Proposed Action, because the uranium-recovery 

44 activities would be identical to those of the Proposed Action, including the vehicular traffic on 

45 county roads. Thus, residents nearest these roads would experience the same noise impacts 

46 as described under the Proposed Action. Workers and wildlife would experience the same 

47 impacts under this Alternative as in the Proposed Action. Mitigation measures for noise impacts 

48 under Alternative 3 would be same as well. Thus, although the impacts from noise associated 

49 with Ross Project construction, operation, aquifer restoration, and decommissioning would be 
DRAFT Environmental Impacts and Mitigation Measures

4-71

1 slightly lower than those described above for the Proposed Action because of the slightly 

2 greater distance to receptors, the noise impacts of the North Ross Project would be SMALL to 

3 MODERATE.

4

5 4.9 Historical, Cultural, and Paleontological Resources

6

7 As discussed in GEIS Section 4.4.8, potential environmental impacts to cultural resources, 

8 which are defined in the GEIS as historical, cultural, archaeological, and traditional cultural 

9 properties (TCPs), could occur during all phases of an ISR facility’s lifecycle (i.e., during 

10 construction, operation, aquifer restoration, and decommissioning) (NRC, 2009). As described 

11 in SEIS Section 1.7.3.2 and SEIS Section 3.9, the NRC staff’s National Historic Preservation Act 

12 (NHPA) Section 106 consultation process for identifying and evaluating historical and cultural

13 resources that could be adversely affected by the Proposed Action is still ongoing. Table 3.18

14 lists the 25 historic and cultural properties that have been identified to-date within the Ross 

15 Project area. The NRC staff’s evaluations to determine whether these properties are eligible for 

16 listing on the National Register of Historic Places (NRHP) are ongoing. Additionally, the Ross 

17 Project area is located between mountains considered sacred by various Native American 

18 cultures (the Big Horn Mountains to the west and the Black Hills and Devils Tower to the east). 

19 Additional sites of Tribal religious and cultural significance, therefore, could potentially be 

20 identified during a TCP survey of the Ross Project area that would be conducted by Tribes and 

21 that is currently being coordinated by the NRC staff in consultation with the Tribes and the 

22 Applicant (see SEIS Section 1.7.3.2). Once more information becomes available regarding the 

23 historical and cultural resources that could be adversely affected by the Ross Project and any 

24 mitigation measures that would be agreed to by the Applicant to reduce the adverse effects, this 

25 SEIS will be revised accordingly. 

26

27 4.9.1 Alternative 1: Proposed Action

28

29 Alternative 1, the Proposed Action, consists of four phases: construction, operation, aquifer 

30 restoration, and decommissioning of the Ross Project facility and wellfields. The impacts of the 

31 Ross Project would include the potential to disturb or destroy historical, cultural, and 

32 paleontological resources, including NRHP-eligible archaeological sites. In general, adherence 

33 to strict mitigation measures can avoid or minimize impacts. These measures could include 

34 avoidance, where practical, of NRHP-eligible sites through adjustments in the Ross Project’s 

35 design, timely consultations with Wyoming State Historic Preservation Office (SHPO) and 

36 affected Tribes, and mandated protocols when inadvertent discovery(ies) of unrecorded 

37 resources are unearthed during ground-disturbing activities. Once site identification and 

38 evaluation is complete, mitigation measures to avoid, minimize, or mitigate adverse impacts to 

39 historical, cultural, and paleontological resources and to plan for inadvertent discovery of 

40 cultural materials or human remains would be developed in consultation with the Wyoming 

41 SHPO, the affected Tribes, and the Applicant.

42

43 4.9.1.1 Ross Project Construction

44

45 Construction of the Proposed Action could disturb up to 113 ha [280 ac], or 16 percent, of the 

46 total Ross Project area. As noted in GElS Section 4.4.8, most of the potential for direct and 

47 indirect adverse impacts to NRHP-eligible properties, traditional culturally significant sites, and 

48 paleontological materials would likely occur during ground-disturbing activities during 

49 construction or decommissioning (NRC, 2009). 
DRAFT Environmental Impacts and Mitigation Measures

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1 Ground-disturbing activities during construction with the potential to destroy the spatial integrity 

2 of archaeological sites and to damage artifacts as well as paleontological resources include, but 

3 are not limited to, grading or excavation for roads and parking lots; pipes, wells, and wellfields; 

4 buildings and structures; domestic-sewage facilities; utility transmission lines and poles; facility 

5 lighting; and surface impoundments. Buried archeological and cultural features as well as 

6 deposits of paleontological resources that are not visible on the surface during the initial 

7 cultural-resource inventories could be exposed during earth-moving activities. Other potential 

8 impacts come from compaction of the soil by heavy equipment, causing damage to subsurface 

9 site integrity by crushing or scattering artifacts or features.

10

11 Certain paleontological specimens have been located at the Ross Project area; however, they 

12 are believed not to be in situ (i.e., they had already been disturbed). Ground disturbance in 

13 excess of a few feet during construction could have a limited impact on the geological units 

14 themselves, including the Lance Formation, which have the potential to contain a variety of 

15 fossils. In addition, increased access to surface-evident archaeological sites during construction 

16 could result in vandalism. TCPs could be affected by temporary visual and aural intrusions. 

17

18 The mitigation measures related to historical and cultural resources would include the standard 

19 industry practices that are described in GEIS Section 4.4.8. In addition, consultation by the 

20 NRC with the Wyoming SHPO, the Tribes, and the Applicant would result in an agreement 

21 clearly delineating the measures the Applicant would take to avoid, minimize, or mitigate 

22 adverse effects to historical, cultural, and paleontological resources and to plan for inadvertent 

23 discovery of cultural materials or human remains. The NRC staff concludes that the impacts to 

24 historical and cultural resources at the Ross Project site would range from SMALL to LARGE. 

25 This finding reflects the fact that the highest potential for adverse effects to historical and 

26 cultural resources would take place during the construction phase, as well as the fact that efforts 

27 to identify and evaluate historic and cultural properties and to determine effects and mitigation 

28 are incomplete and Section 106 consultation is ongoing.

29

30 4.9.1.2 Ross Project Operation

31

32 Direct and indirect adverse impacts on archaeological sites, NRHP-eligible historical properties, 

33 TCPs, and paleontological resources are expected to be minimal during the operation phase of 

34 the Ross Project. Impacts would be mitigated prior to facility construction and Ross Project 

35 operation is generally limited to previously disturbed areas (except continuing wellfield 

36 installation). Visual or aural impacts from uranium-recovery operation at the Ross Project to 

37 traditional cultural resources located within the Ross Project area and other cultural landscapes,

38 which would be identified before construction, would be expected to continue during operation. 

39 Therefore, the impacts to historical and cultural resources during Ross Project operations would 

40 be SMALL. 

41

42 4.9.1.3 Ross Project Aquifer Restoration

43

44 Impacts to archaeological sites, NRHP-eligible historical properties, TCPs, and paleontological 

45 resources from aquifer restoration would be similar to those expected during uranium-recovery 

46 operation. These impacts would primarily result from the surface disturbance associated with 

47 operation, maintenance, and repair of existing wellfields as part of the aquifer-restoration 

48 process as well as on-going visual or aural impacts. Therefore, the impacts to historical and 

49 cultural resources during aquifer restoration would be SMALL. 
DRAFT Environmental Impacts and Mitigation Measures

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1 4.9.1.4 Ross Project Decommissioning

2

3 Surface-disturbing activities would temporarily increase during the Ross Project’s 

4 decommissioning. As during construction, ground disturbance in excess of a few feet during 

5 facility decommissioning would have an impact on the geological units themselves, including the 

6 Lance Formation, which has the potential to contain a variety of fossils. However, most of the 

7 decommissioning activities would focus on previously disturbed areas and, therefore, most of 

8 the historic, cultural, and paleontological resources would already be known as a result of the 

9 investigations that would be conducted prior to construction. Unavoidable visual and aural 

10 impacts, however, could increase temporarily during the decommissioning of the Proposed 

11 Action. Therefore, the impacts to historical and cultural resources during decommissioning 

12 would be SMALL. 

13

14 4.9.2 Alternative 2: No Action

15

16 Under the No-Action Alternative, the Ross Project would not be licensed and the land would 

17 continue to be available for other uses. Under the No-Action Alternative, no major disturbance 

18 of land and concomitant potential impacts to historic, cultural, and paleontological resources 

19 would occur, except for natural processes such as erosion, although some preconstruction 

20 activities could potentially disturb historic, cultural, and/or paleontological resources. The 

21 impacts to historical and cultural resources under Alternative 2 would be SMALL. 

22

23 4.9.3 Alternative 3: North Ross Project

24

25 Under Alternative 3, the North Ross Project would generally be the same as the Proposed 

26 Action, except that the facility (i.e., the CPP, associated buildings, and auxiliary structures as 

27 well as the surface impoundments) would be located to the north of where it would be located in 

28 the Proposed Action, as described in SEIS Section 2.1.3. Any impacts to historical, cultural, or 

29 paleontological resources from the construction, operation, aquifer restoration, and 

30 decommissioning of the Ross Project under Alternative 3 could occur as described in the 

31 Proposed Action. Therefore, the impacts to historical and cultural resources due to Alternative 3 

32 also would be SMALL to LARGE during construction and SMALL during operation, aquifer 

33 restoration, and decommissioning. However, as with the Proposed Action, mitigation measures 

34 such as avoidance would be developed prior to construction and would reduce the construction 

35 impacts.

36

37 4.10 Visual and Scenic Resources

38

39 The Proposed Action could impact visual and scenic resources during all phases of the Project’s 

40 lifecycle. The visual-resources impacts analysis below is an evaluation of the landscape 

41 changes that could occur as a result of the Proposed Action. Most of the visual and scenic 

42 impacts would be associated with construction activities, which would be short term, as well as 

43 with the new buildings and roads, which would exist until all phases of the project are 

44 completed. The Ross Project would introduce new elements of form, line, color, and texture into 

45 the landscape of the Ross Project area. Because of the small surface footprint (only 113 ha 

46 [280 ac]) and low profile of the uranium-recovery facility and wellfields, no major visual or 

47 scenic impacts would be expected to occur.
DRAFT Environmental Impacts and Mitigation Measures

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1 The visual-resources study area for the Ross Project is currently categorized by Strata as a 

2 VRM Class III, according to the BLM scale noted in SEIS Section 3.10. Consequently, the level 

3 of change to the characteristic landscape in Class III areas can be moderate (BLM, 2010). 

4

5 4.10.1 Alternative 1: Proposed Action

6

7 Alternative 1 consists of four phases: construction, operation, aquifer restoration, and 

8 decommissioning of an ISR uranium-recovery facility and wellfields. Potential visual and scenic 

9 impacts at the proposed Ross Project could result from earth moving and surface disturbance 

10 as well as the construction, operation, and decommissioning of the following: 1) wellfields 

11 (including drill rigs, wellhead covers, header houses, and roads); 2) the CPP; 3) the surface 

12 impoundments; 4) the CBW; 5) secondary and tertiary access roads; 6) power and utility lines; 

13 and 7) fencing. The visual impacts from these site components would, however, be consistent 

14 with the BLM VRM Class III designation (NRC, 2009). 

15

16 4.10.1.1 Ross Project Construction

17

18 GEIS Section 4.4.9 noted that visual-resource impacts could result from heavy equipment use 

19 (drill-rig masts and cranes), dust and hydrocarbon emissions, and hillside and roadside cuts into 

20 the native topography during construction. In addition, construction activities within a rural

21 setting could give the area a more industrial appearance, thereby decreasing the local visual

22 appeal. However, at the proposed site the existing landscape already includes visual alterations 

23 as a result of oil recovery, existing roads, and existing utilities. Construction activities would be 

24 short term, and following completion of facility construction, many of the areas where temporary 

25 ground disturbance has occurred would be reclaimed and restored to the pre-licensing baseline

26 conditions.

27

28 The largest visible surface features of the Proposed Action that would emerge during the 

29 construction phase would include the CPP and surface impoundments, wellhead covers and 

30 header houses; electrical and other utility distribution lines, which are mounted on 6-m [20-ft] 

31 wooden poles; and more roads. The Applicant proposes to use both existing and new roads to 

32 access each wellfield and the ISR facility itself (i.e., the CPP and surface impoundments) (see 

33 SEIS Section 3.10). 

34

35 Short-term visual contrasts with the characteristic landscape of the Proposed Action would also 

36 result from actual activities associated with construction of the Ross Project. Site clearing and 

37 grading; facility and surface impoundment construction and wellfield installation; access road 

38 construction; vehicular and pedestrian traffic increases; and underground and overhead pipeline 

39 and utilities installation all would result in visual contrasts to the color of the Ross Project area. 

40 Irregularity of the natural landscape would occur during the construction phase. Construction 

41 activities would typically occur during daylight hours and would be consequently visible, with the 

42 exception of some drilling and equipment maintenance that could occur at night (Strata, 2011a). 

43

44 Wellfield construction would involve the use of drill rigs, water trucks, backhoes, supply trailers,

45 and passenger vehicles. This equipment would be temporarily concentrated at each well or 

46 wellfield. A typical truck-mounted drill rig can be about 9 – 12 m [30 – 40 ft] tall and would be

47 the most visible piece of equipment used in wellfield construction. Once a well is completed

48 and developed for use, the drill rig would be moved to a new location. Strata anticipates that

49 up to 12 drill rigs could be operated at one time during wellfield construction. As with the 
DRAFT Environmental Impacts and Mitigation Measures

4-75

1 construction activities above, drilling would primarily occur during daylight hours; however, it is

2 possible drilling would continue into the night. For nighttime operation, the drill rigs would

3 be lighted, increasing the potential visual impacts.

4

5 Additional construction impacts would include visible fugitive dust that would be generated 

6 during ground clearing and grading for header houses and drilling pads; access roads and 

7 parking lots; storage and laydown pads; the CPP, auxiliary structures, and surface 

8 impoundments; injection, recovery, and monitoring wells; and pipelines. In addition, the drill 

9 rigs, trucks, and other vehicles employed during the construction phase at the Ross Project 

10 could potentially emit visible emissions (see SEIS Section 3.7.3). These impacts would be 

11 temporary and short-term. In the long term (i.e., greater than one year), as major construction 

12 activities are completed, fugitive dust and vehicle emissions would decrease.

13

14 The Applicant would mitigate visual and scenic impacts related to fugitive dust by wetting the 

15 soil and using chemical dust suppressants, as necessary, when clearing and grading activities 

16 are underway as well as by establishing diminished speed limits for vehicle traffic, strategically 

17 placing water load-out facilities near access roads, encouraging personnel to carpool, and 

18 selecting road surfaces that would minimize fugitive dust. Following completion of wellfield 

19 installation, disturbed areas would be reclaimed and restored within a single construction 

20 season, if at all possible (Strata, 2011a). These mitigation measures are discussed in more 

21 detail in SEIS Section 4.7.1.1.

22

23 The viewshed analysis introduced in SEIS Section 3.10.1 demonstrates that the Ross Project 

24 would not be visible from the base of Devils Tower or from the Visitor’s Center. The Proposed 

25 Action would be visible (as determined by the cross-section shown in Figure 3.21 in SEIS 

26 Section 3.10.1) to climbers scaling the Tower. During initial construction, fugitive dust, other 

27 emissions, and construction traffic could impact the viewshed for the Devils Tower climbers. As 

28 major construction activities are completed, however, fugitive dust and other emissions would 

29 decrease. The Ross Project would not be visible from Keyhole State Park, Black Hills National 

30 Forest, or Thunder Basin National Grassland during any phase of the Project due to the long 

31 distances between these recreational areas and the Ross Project as well as to the screening 

32 effects of topography (Strata, 2011a). 

33

34 The Applicant would mitigate visual impacts during its construction activities by phasing 

35 construction activities; limiting the extent of land disturbance at any one time; promptly restoring 

36 and reseeding disturbed areas; using existing roads wherever possible; following existing 

37 topography during access road construction to minimize cut and fill and thus reduce contrast; 

38 minimizing secondary and tertiary access road widths; and locating access roads, pipelines, and 

39 utilities in common corridors (Strata, 2011a). 

40

41 Prior to construction of the Ross Project, baseline monitoring for potential light pollution would 

42 be conducted at eight sites. Based on the results of this preconstruction baseline evaluation, a 

43 light-pollution monitoring plan would be prepared by the Applicant. This plan would finalize the 

44 locations for both continuous and intermittent light sources; in addition, it would provide a 

45 schedule for periodic checks on sky brightness during the construction and operation of the 

46 Ross Project to ensure worker safety and to measure, and to mitigate if necessary, obtrusive 

47 light emanating from the Proposed Action (Strata, 2012a).
DRAFT Environmental Impacts and Mitigation Measures

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1 The Applicant proposes the following mitigation measures to limit light-pollution impacts at the 

2 Ross Project:

3

4 ■ Designing lighting plans with an emphasis on the minimum lighting requirements for 

5 operation, safety, and security purposes;

6 ■ Using light sources of minimum intensity (as measured in lumens) necessary to accomplish 

7 the light's purpose;

8 ■ Specifying lighting fixtures that direct light only where it is needed (i.e., shine down, not out 

9 or up) in conjunction with shielding that further directs the light towards the respective work 

10 area;

11 ■ Turning lights off when not needed at proposed intermittent light locations either manually,

12 with timers, or occupancy sensors;

13 ■ Adjusting the type of lights used so that the light waves emitted are those that are less likely 

14 to cause light-pollution problems such as those attendant with high-pressure sodium lamps;

15 ■ Fitting building windows with shutters, where appropriate, to block light emissions, including 

16 the CPP and other buildings;

17 ■ Using natural and/or in situ screens to reduce perceptible light (i.e., locating buildings and 

18 other facility components to take advantage of the natural topography and any trees; and

19 ■ Evaluating the results of the light-pollution monitoring to ensure that, as necessary, the 

20 mitigation measures suggested previously have been implemented successfully (Strata, 

21 2012a).

22

23 Finally, the Applicant is committed to evaluating the extent of the light pollution to nearby 

24 residences following installation of the final lighting system. Additionally, the Applicant is 

25 committed to acting on any concerns of local residents as long as worker safety is not 

26 compromised (Strata, 2012a).

27

28 Because the management objective of VRM Class III is to partially retain the existing character

29 of the landscape so that the level of change to the characteristic landscape can be moderate, 

30 the impacts from the Ross Project’s construction are in fact consistent with VRM Class III. Thus, 

31 in the short-term (i.e., less than one year), construction activities at the proposed Ross Project 

32 would result in SMALL to MODERATE visual impacts to the nearest four residences, each of 

33 which has a view of the Ross Project area. For the remaining 7 of the 11 nearby residences, 

34 however, the visual impacts would be SMALL. 

35

36 4.10.1.2 Ross Project Operation

37

38 SEIS Section 2.1.1 describes the Proposed Action’s uranium-recovery operation. Most of the 

39 wellfield and surface infrastructure would have a low profile, and most piping and cables would 

40 be buried. The irregular layout of wellfield surface structures, such as wellhead covers and 

41 header houses, would further reduce visual contrast. Because uranium-recovery operations are 

42 generally located in sparsely-populated areas, typically in generally rolling topography, most 

43 visual impacts during facility and wellfield operation would not be visible from more than 
DRAFT Environmental Impacts and Mitigation Measures

4-77

1 approximately 1 km [0.6 mi] away. As described in GEIS Section 4.4.9.2, the potential visual 

2 and scenic impacts from uranium-recovery operation are SMALL. 

3

4 At the Ross Project, wellhead covers and header houses (wellhead covers would be typically 

5 low at approximately 1 – 2 m [3 – 6 ft] high), the CPP and auxiliary buildings, the surface 

6 impoundments, access roads, buried utilities, and unburied facility lighting and power lines 

7 would be similar to those discussed in the GEIS and, therefore, the potential impacts to the 

8 visual resources during Ross Project operation would also be SMALL. Most of the pipelines 

9 and cables associated with wellfield operation are anticipated to be buried to protect them from 

10 freezing; thus, they would not be visible during the Proposed Action’s operation. Other potential 

11 impacts include the conduct of wellfield activities, such as monitoring-well sampling, module12 building inspections, and mechanical-integrity testing; these impacts would also be SMALL. 

13 Because the location of the uranium ores underlying the Ross Project are typically irregular, the 

14 network of pipes, wells, and power lines (6 m [20 ft] tall) would not be regular in pattern or 

15 appearance (i.e., not a grid); this lack of a pattern would reduce visual contrast and associated 

16 potential impacts. The overall visual impact of an operating wellfield would be SMALL (NRC, 

17 2009).

18

19 Because the uranium-recovery processing and support facilities, such as the CPP, offices, and 

20 maintenance buildings, would be located in one area, they would be more noticeable to the 

21 casual observer due to their size and density. The CPP would be the largest structure. These 

22 components would be prominent in the foreground and middle-ground views, and they would be 

23 silhouetted in the background view from public access points (i.e., the adjacent county roads). 

24 As described in SEIS Section 3.10, however, the Proposed Action would be located in gently 

25 rolling topography, where the visibility of aboveground infrastructure would vary and would be 

26 relative, depending upon the location and elevation of an observer as well as on nearby 

27 topography, total distance, and lighting characteristics. 

28

29 Lighting from the Ross Project would be visible from five of the residences to the east and from 

30 various locations directly to the west, north, and southeast. Figure 3.22 in SEIS Section 3.10.2 

31 shows where lighting emanating from the Proposed Action would be visible within the 3-km [2-

32 mi] vicinity surrounding the Project area. Mitigation measures for local light-pollution impacts 

33 would be the same as those described above for the construction phase of the Ross Project.

34

35 In addition to the mitigation measures employed during the Proposed Action’s construction 

36 phase, the Applicant identifies a number of additional mitigation measures to reduce the visual 

37 impacts during its operation. The wellhead-cover color would be selected to blend with the 

38 environment. Pipelines and electrical lines between the wells and module buildings would be 

39 buried as new wellfields come online, and disturbed areas would be immediately reclaimed, 

40 reseeded, and restored. The electrical-distribution poles would be wooden so that the natural 

41 color would tend to blend with the landscape. Another mitigation measure for screening the 

42 CPP and surface impoundments would include the Applicant’s planting trees at a density that 

43 would limit views into the Project area from public roads and nearby residences. The tree 

44 species would be a conifer or another species native to the area. The approximate tree 

45 locations are depicted on Figure 4.3. 

46

47 Thus, the impacts to visual and scenic resources during the operation of the Proposed Action 

48 would be SMALL.
DRAFT Environmental Impacts and Mitigation Measures

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1 4.10.1.3 Ross Project Aquifer Restoration

2

3 GEIS Section 4.4.9 concluded that the visual impacts during aquifer restoration would be similar 

4 to those experienced during uranium-recovery operation, and therefore the impacts would be 

5 SMALL (NRC, 2009). Much of the same equipment and infrastructure used during Ross Project 

6 operation would be employed during aquifer restoration, so that impacts to the visual landscape 

7 would be expected to be similar to or less than the impacts during the Proposed Action’s 

8 operation phase. In the wellfields, the greatest source of visual contrast would be from 

9 equipment used as injection and production wells are being plugged and abandoned during the 

10 natural sequence of the installation of a new wellfield(s) and restoration of the aquifer in a spent 

11 wellfield(s). Because there is no active drilling in any wellfield undergoing aquifer restoration, 

12 potential visual impacts during this phase would be expected to be less than those during facility 

13 construction and wellfield installation, and these impacts would be of short duration. 

14

15 The mitigation measures presented for both the Proposed Action’s construction and operation 

16 phases would continue to be implemented during the aquifer-restoration phase, and these 

17 would continue to limit potential visual impacts. Vehicular traffic during the aquifer-restoration 

18 phase would be much more limited: worker commutes would diminish significantly (i.e., from a 

19 workforce of 200 persons to one of 20 persons during aquifer restoration) and there would be

20 fewer deliveries of supplies. There would also be a decreasing-to-zero frequency of offsite and 

21 potential onsite yellowcake shipments as aquifer restoration proceeds. Therefore, fewer trips 

22 would occur than during the earlier phases, with concomitant lower levels of fugitive dust and 

23 combustion engine emissions as de facto mitigation measures.

24

25 Because aquifer-restoration activities at the Ross Project would be very similar to those 

26 described in the GEIS (NRC, 2009), the impacts of the Project during the aquifer-restoration 

27 phase would also be SMALL.

28

29 4.10.1.4 Ross Project Decommissioning

30

31 As discussed in GEIS Section 4.4.9.4, the impacts on visual and scenic resources during the 

32 decommissioning of an ISR facility would be SMALL (NRC, 2009). The Proposed Action would 

33 not cause any significant impacts to the landscape that would persist after facility 

34 decommissioning and site restoration are completed. Most visual impacts during 

35 decommissioning would be temporary and diminish as structures, equipment, and other facility 

36 components are removed; the disturbed land surface is reclaimed and restored; and the 

37 vegetation is re-established. NRC licensees are required to conduct final decommissioning and 

38 site restoration under an NRC-approved decommissioning plan, with the goal of returning the 

39 landscape to the visual conditions of the area prior to any NRC-licensed activities. While some 

40 roadside cuts and hill-slope modifications could persist beyond facility and wellfield 

41 decommissioning and site restoration (depending upon a landowner’s wishes), the re42 contouring, re-vegetating, and restoring of the Ross Project area would consist of the same 

43 activities described in the GEIS and, hence, the visual and scenic impacts from the Proposed 

44 Action’s decommissioning would be SMALL. 

45

46 When the Ross Project’s decommissioning efforts have been accepted by the NRC, all buildings 

47 and equipment would have been decontaminated, dismantled, decommissioned, and either 

48 disposed of or relocated to another facility. Site reclamation efforts would be designed to return 

49 the visual landscape of the Ross Project to its baseline contours. Re-contouring of disturbed 
DRAFT Environmental Impacts and Mitigation Measures

4-79

1 areas on the Ross Project (including access roads) and the reseeding of those areas with native 

2 vegetation or an approved seed mix would both be accomplished during site restoration. All of 

3 these activities would minimize any permanent impacts on visual and scenic resources.

4

5 The Applicant would mitigate the fugitive-dust impacts that could result from decommissioning 

6 activities by its use of water spray during dismantling and demolition activities and on 

7 unimproved roads to reduce dust emissions (Strata, 2011a). Areas of disturbance would be 

8 restored and reseeded to the pre-construction condition. All facility-decommissioning and site9 restoration activities would be done in accordance with NRC and WDEQ/LQD guidelines. Once 

10 these activities are complete, the visual landscape would have been returned to its pre11 construction, pre-operational condition.

12

13 4.10.2 Alternative 2: No Action

14

15 Under the No-Action Alternative, the Ross Project would not be licensed and the land would 

16 continue to be available for other uses. Therefore, there would be no change to the existing 

17 visual and scenic resources at the Ross Project area. In general, the existing site conditions 

18 and land uses would persist. All existing roads, fences, utilities, landscape formations, and 

19 vegetation would remain. No additional structures or land uses associated with the Ross 

20 Project would be introduced to affect the existing viewscapes, and the existing scenic quality 

21 would be unchanged. The visual resource classification would remain BLM Class III, as 

22 described in SEIS Section 3.10. Thus, visual and scenic impacts would be SMALL.

23

24 4.10.3 Alternative 3: North Ross Project

25

26 Under Alternative 3, the North Ross Project would generally be the same as the Proposed 

27 Action, except that the facility (i.e., the CPP, associated buildings, and auxiliary structures as 

28 well as the surface impoundments) would be located to the north of where it would be located in 

29 the Proposed Action, as described in SEIS Section 2.1.3. The Alternative 3 facility would 

30 remain within the Ross Project area, albeit in a location that is more shielded by topographical 

31 features than where it would be located in the Proposed Action. Thus, some of the Ross Project 

32 views from neighboring properties would be diminished, and the nearby residences would be 

33 more shielded from light pollution than they would be under the Proposed Action. As a result, 

34 the visual- and scenic-resource impacts would, at the least, not differ from those of the 

35 Proposed Action and, most likely, they would be reduced from those of the Proposed Action. 

36 Therefore, the visual-resource impacts would be SMALL to MODERATE in the short-term and 

37 SMALL in the long-term.

38

39 4.11 Socioeconomics

40

41 The Proposed Action could impact local socioeconomics during all phases of the Project’s 

42 lifecycle. During socioeconomic impact analyses, several areas are examined; these include 

43 employment, demographics, income, housing, finance, education, and social and health 

44 services.
DRAFT Environmental Impacts and Mitigation Measures

4-80

1 4.11.1 Alternative 1: Proposed Action

2

3 Alternative 1, the Proposed Action, consists of four phases: construction, operation, aquifer 

4 restoration, and decommissioning of a uranium-recovery facility and wellfields.

5

6 4.11.1.1 Ross Project Construction

7

8 The Ross Project would employ approximately 200 people during construction (Strata, 2012a). 

9 The peak construction workforce of 200 workers is within the range of the construction 

10 workforce estimates provided in the GEIS (i.e., also 200 workers) (NRC, 2009). The GEIS 

11 assumed that the majority of the construction personnel positions would be filled by skilled 

12 workers from outside the NSDWUMR and that this influx of workers would be expected to result 

13 in SMALL to MODERATE socioeconomic impacts, with impacts the greatest for communities 

14 with small populations (NRC, 2009). However, due to the short duration of construction, the 

15 GEIS also noted that these workers would have only a limited effect on public services and 

16 community infrastructure. Further, construction workers would be less likely to relocate their 

17 families to another region, and if the majority of the construction workforce would be filled from 

18 within the region of the facility, socioeconomic impacts would be SMALL (NRC, 2009). 

19

20 Because the size of the Ross Project’s construction workforce is of similar size to that presented 

21 in the GEIS, and the Applicant is committed to hiring locally—it projects that 90 percent of the 

22 construction workforce would be local hires (Strata, 2012a)—the employment, demographic, 

23 income, housing, education, and health and social services impacts during the construction 

24 phase of the Ross Project would be SMALL: Employment increases would represent only 1.2 

25 percent of all jobs in the Region of Influence (ROI) (i.e., Crook and Campbell Counties). The 

26 population increases, and consequent increases in public and private services, would represent 

27 only a 0.1 percent increase over pre-licensing baseline levels. MODERATE impacts are 

28 projected for the finance sector as a result of the additional property-tax revenues generated by 

29 the Project (see Table 4.6).

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48 Source: Strata, 2012a.

Table 4.6

Estimated Major Tax Revenues

Tax Revenues

Revenue Source

Average

Per Year

Over 

10 Years

Severance Taxes $855,000 $8,550,000

State Royalties $243,000 $2,430,000

Gross Production Taxes $1,337,000 $13,370,000

Property Taxes $350,000 $3,500,000

TOTAL $2,785,000 $27,850,000
DRAFT Environmental Impacts and Mitigation Measures

4-81

1 The following sections provide impact estimates for each of the specific resource areas within 

2 socioeconomics during all phases of the Ross Project.

3

4 Employment

5

6 The 200 construction workers that would be employed at the proposed Ross Project could 

7 generate an additional 140 indirect jobs in the ROI (NRC, 2009), for a peak employment impact 

8 of 340 workers as a result of the Project’s construction phase. With an employment base in the 

9 ROI of 28,842 workers (see SEIS Section 3.11.4), impacts on the Region’s employment would 

10 be SMALL, representing approximately 1.2 percent of all jobs in the two Counties.

11

12 Demographics

13

14 It is estimated that less than 10 percent of the construction workforce would come from outside 

15 the immediate Ross Project vicinity, or approximately 20 workers (Strata, 2012a). As workers 

16 could potentially travel from anywhere in the U.S., based upon the average household size of 

17 2.58 for the U.S. (USCB, 2012), this would translate into 52 additional residents in the ROI. It is 

18 likely that most new construction workers for the Ross Project would not relocate their families, 

19 however for the purposes of this SEIS, it is assumed that they would move their families. This 

20 number is less than 0.1 percent of the combined population base of 53,216 persons in Crook 

21 and Campbell Counties as of 2010 (see SEIS Section 3.11.1). This would be a SMALL 

22 demographic impact.

23

24 Income

25

26 It is expected that workers would be paid the regional rates typical of Crook and Campbell 

27 Counties, where a higher percentage of jobs are in the relatively higher-paying energy industry. 

28 Based upon a weighted-average annual earnings per job of $61,400 (see SEIS Section 3.11.2), 

29 the 200 workers would generate approximately $12.3 million in annual earnings. With an 

30 estimated $2.6 billion in total personal income in both Crook and Campbell Counties, the 

31 impacts of the construction of the Ross Project on local income would represent less than 1 

32 percent of total income in the two Counties and would be a SMALL impact.

33

34 Housing

35

36 According to GEIS Section 4.4.10, the impacts to housing from ISR-facility construction would 

37 be expected to be SMALL (and short term), even if the workforce were to be primarily filled from 

38 outside the region (NRC, 2009). It is likely, however, that the majority of workers would use 

39 temporary housing such as apartments, hotels, or trailer camps (NRC, 2009). At the maximum, 

40 if the additional 20 new workers to the Ross Project vicinity represent a demand for 20 housing 

41 units in the ROI (see above), this additional demand for housing would represent less than 0.1 

42 percent of the total housing stock of 22,550 units in the region (see SEIS Section 3.11.3), and 

43 this would be a SMALL impact.

44 Finance

45

46 As noted in GEIS Section 4.4.10, the construction of an ISR facility could have a MODERATE 

47 impact on finances within a ROI (NRC, 2009). Local-government finances would be affected by 

48 ISR-facility construction by the additional taxes collected and the purchase of goods and 
DRAFT Environmental Impacts and Mitigation Measures

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1 services in support of construction activities. Although Wyoming does not have an income tax, 

2 it does have a state sales tax, a lodging tax, and a use tax. Construction workers would 

3 contribute to these as they purchase goods and services within the Ross Project ROI, while they 

4 work on the construction of the Proposal Action. Based on a valuation of $50 million for the 

5 Ross Project facility and wellfields, as well as the related and real property, multiplied by an 11.5 

6 percent assessment ratio and the Crook County mill levy of 0.062545, local property taxes that 

7 would accrue to Crook County would be estimated to be approximately $350,000 per year, 

8 reflecting approximately 13 percent of Crook County property-tax collections (Strata, 2012a). 

9 These benefits would be offset, however, by the cost of additional public services required by 

10 the new residents in the vicinity. This additional demand would be associated with just the 

11 estimated 52 additional residents in the ROI, representing less than 0.1 percent of the 

12 population in the two Counties; the additional cost for public services also would represent less 

13 than a 0.1 percent increase in local-government expenditures. Because the size and scale of 

14 the Ross Project is similar to that described in the GEIS, and given the foregoing information, 

15 the impacts to local finance would be MODERATE. 

16

17 Education

18

19 As discussed above, it is likely that most new construction workers for the Ross Project would 

20 not move their families. However, at a maximum, if all 20 workers were to bring their families, 

21 and based upon a school-age population representing 20.4 percent of the population nationwide 

22 (USCB, 2012), the 52 additional residents in the Ross Project vicinity would generate 11 

23 additional elementary and secondary students in the ROI schools. This would represent less 

24 than 0.1 percent of the total enrollment in area schools and would represent a SMALL impact on 

25 education.

26

27 Health and Social Services

28

29 Increased demand for health and social services is a function of the additional population in the 

30 ROI. As discussed above, the population increase in the ROI due to construction activities 

31 would represent less than a 0.1 percent increase in the local population because most workers 

32 would already reside within a commuting radius of the Project. Thus, only a 0.1 percent 

33 increase in the demand for health and social services would occur, and this increased demand 

34 for such services would represent a SMALL impact. 

35

36 In addition, as noted in the GEIS, accidents resulting from construction of the Proposed Action 

37 would not be expected to be different than those from other types of similar industrial facilities 

38 (NRC, 2009). In the case of an industrial accident, the Applicant would commit to maintaining 

39 emergency-response personnel on staff and would train local emergency responders in 

40 preparing and responding to potential environmental, safety, and health emergencies resulting 

41 from Ross Project construction (Strata, 2011a), thereby minimizing any potential decrease in or 

42 impact to the availability of local emergency health services.

43 4.11.1.2 Ross Project Operation

44

45 The Ross Project would employ approximately 60 people during its operation (Strata, 2012a). 

46 This number is within the range of the operation-workforce estimates provided in the GEIS (50 –

47 80 workers) (NRC, 2009). According to the GEIS, if the majority of the operation workforce is 

48 filled by personnel from outside the area, potential population and public services impacts would 
DRAFT Environmental Impacts and Mitigation Measures

4-83

1 range from SMALL to MODERATE, depending upon the proximity of the ISR facility to 

2 population centers (NRC, 2009). However, because an outside workforce would be more likely 

3 to settle in more populated areas, with increased access to housing, schools, services, and 

4 other amenities, these impacts could be reduced (NRC, 2009). If the majority of the workforce 

5 during ISR-facility operation is of local origin, the potential impacts to population and public 

6 services would be expected to be SMALL (NRC, 2009). 

7

8 Because the size of the Ross Project’s proposed workforce during the operation of the Ross 

9 Project would be within the range evaluated in the GEIS, and because the Applicant would 

10 commit to hiring locally—80 percent of the operation workforce would be expected to be local 

11 hires (Strata, 2012a)—the employment, demographic, income, housing, education, and health 

12 and social services impacts during the Ross Project’s operation phase would be SMALL. 

13 Employment and population increases, and consequent increases in public and private 

14 services, would represent less than 1 percent over pre-licensing baseline levels. MODERATE 

15 impacts, however, would be projected for finance as a result of the additional tax revenues that 

16 would accrue to Crook County (see Table 4.6).

17

18 4.11.1.3 Ross Project Aquifer Restoration

19

20 The GEIS assumed that the workforce during aquifer-restoration activities at an ISR facility 

21 would be the same as the operation phase (i.e., 50 – 80 workers) and, thus, the impacts would 

22 be similar and would be SMALL (NRC, 2009). The Applicant indicates that at the Ross Project 

23 there would be a workforce of 20 – 30 workers during the aquifer-restoration phase , without 

24 concurrent operations (Strata, 2012a), a smaller workforce than that projected in the GEIS. 

25

26 The need for regulatory, management, and health and safety personnel would continue 

27 throughout aquifer restoration, but this need would be met by personnel transitioning from 

28 operation-phase work to aquifer restoration, and no new personnel would necessarily be 

29 required (Strata, 2012a). Thus, the impacts of the Proposed Action’s aquifer-restoration phase 

30 would likely be at most the same, or, would more likely be less than those noted for the Ross 

31 Project’s operation phase. Because the aquifer-restoration workforce at the Project would be 

32 less than that estimated in the GEIS, and with an employment base in Crook and Campbell 

33 Counties of 28,842 workers (see Section 3.2.10.4), the socioeconomic impacts of the Ross 

34 Project on area employment would be SMALL, representing less than 1 percent of all jobs in the 

35 two Counties. Severance tax revenues accruing to local jurisdictions would decrease as 

36 uranium production ceases during this phase of the Ross Project. 

37

38 4.11.1.4 Ross Project Decommissioning

39

40 In GEIS Section 4.4.10, the workforce examined for an ISR facility’s decommissioning was 

41 estimated to be similar to that of the construction phase (i.e., up to 200 persons) and, thus, the 

42 impacts would be similar and would be SMALL to MODERATE, with MODERATE impacts for 

43 areas with small populations (NRC, 2009). The Applicant indicates, however, that about only 90 

44 workers would be required during decommissioning of the Ross Project (Strata, 2011a). Only 

45 12 of these workers would be non-local hires (Strata, 2012a). These personnel generally 

46 represent the regulatory, management, and health and safety personnel that would have been 

47 present at the Ross Project during the earlier Project phases. Because the size of the 

48 workforce for the Ross Project’s decommissioning phase is less than that estimated in the 

49 GEIS, and only 12 workers would be expected to be non-local hires, the overall socioeconomic 
DRAFT Environmental Impacts and Mitigation Measures

4-84

1 impacts of the Proposed Action’s decommissioning phase would be SMALL. Tax revenues 

2 accruing to local jurisdictions would decrease to zero as uranium production is concluded during 

3 decommissioning of the Ross Project. 

4

5 4.11.2 Alternative 2: No Action

6

7 Under the No-Action Alternative, the Ross Project would not be licensed and the land would 

8 continue to be available for other uses. There would be no new jobs created; no changes in 

9 income levels in the ROI; no changes in population; no increased demand for education, health, 

10 or social services; and no changes in local finances. Other forms of energy development in the 

11 ROI would continue to impact regional socioeconomic resources. The economic benefits and 

12 socioeconomic impacts described for the Proposed Action would not accrue to Crook and 

13 Campbell Counties, nor to the State of Wyoming. Thus, the socioeconomic impacts of the No14 Action Alternative would be SMALL.

15

16 4.11.3 Alternative 3: North Ross Project

17

18 Under Alternative 3, the North Ross Project would generally be the same as the Proposed 

19 Action, except that the facility (i.e., the CPP, associated buildings, and auxiliary structures as 

20 well as the surface impoundments) would be located to the north of where it would be located in 

21 the Proposed Action, as described in SEIS Section 2.1.3. The construction of the CPP and 

22 surface impoundments at the north site would not change workforce levels, and therefore the 

23 impacts would be the same as those described under the Proposed Action. Because changes 

24 in employment are the principal driver of socioeconomic impacts, the socioeconomic impacts of 

25 Alternative 3 would be the same as for the Proposed Action, SMALL to MODERATE during 

26 Alternative 3’s construction and operation, and SMALL during aquifer restoration and its 

27 decommissioning.

28

29 4.12 Environmental Justice

30

31 On February 11, 1994, President Clinton signed Executive Order (EO) No. 12898, entitled 

32 Federal Actions to Address Environmental Justice in Minority Populations and Low-Income 

33 Populations, which directs each Federal agency to “... make achieving environmental justice 

34 part of its mission by identifying and addressing, as appropriate, disproportionately high and 

35 adverse human health or environmental effects of its programs, policies, and activities on 

36 minority populations and low income populations” (EOP, 1994). 
DRAFT Environmental Impacts and Mitigation Measures

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1 On December 10, 1997, the Council on Environmental Quality (CEQ) issued its Environmental 

2 Justice Guidance Under the National Environmental Policy Act. The CEQ developed this 

3

4 guidance to “... further 

5 assist Federal agencies 

6 with their National 

7 Environmental Policy Act 

8 (NEPA) procedures.” As 

9 an independent agency, 

10 the CEQ’s guidance is not 

11 binding on the NRC. 

12 However, the NRC 

13 considered the CEQ’s 

14 guidance on 

15 environmental justice in 

16 developing its own 

17 environmental justice 

18 analytical procedures 

19 (NRC, 2003). 

20

21 The CEQ provided the 

22 definitions listed in the text 

23 box to the left in its 

24 Guidance for consistent 

25 use during environmental26 justice analyses (CEQ, 

27 1997). 

28

29 The NRC has required an

30 environmental-justice 

31 analyses be included in its 

32 environmental impact 

33 statements (EISs) (NRC, 

34 2004; NRC, 2003, 

35 Appendix C). NRC 

36 environmental-justice 

37 guidance discusses the 

38 procedures to evaluate 

39 potential 

40 disproportionately high 

41 and adverse impacts 

42 associated with physical, 

43 environmental, 

44

45

46

What is the terminology used during an environmentaljustice analysis ?

■ Low-Income Populations

These populations are identified by annual statistical poverty thresholds 

from the U.S. Census Bureau (USCB). In identifying low-income 

populations, agencies may consider a community as either a group of 

individuals living in geographic proximity to one another or a set of 

individuals (such a migrant workers or Native Americans), where either 

type of group experiences common conditions of environmental exposures

or impacts.

■ Minority Individuals

Minority individuals are those who identify themselves as members of the 

following population groups: Hispanic or Latino, American Indian or 

Alaska Native, Asian, Black or African American, Native Hawaiian, or 

Other Pacific Islander or are two or more races, meaning individuals who 

identified themselves on a Census form as being a member of two or 

more races, for example, Hispanic and Asian.

■ Minority Populations

Minority populations must be identified when the minority population of an 

affected area exceeds 50 percent or the minority-population percentage of 

the affected area is meaningfully greater than the minority-population 

percentage in the general population or other appropriate unit of 

geographic analysis.

■ Disproportionately High and 

Adverse Human Health Effects

Adverse health effects are measured in risks and rates that could result in 

latent cancer fatalities as well as other fatal or nonfatal adverse impacts 

on human health. Adverse health effects may include bodily impairment, 

infirmity, illness, or death. Disproportionately high and adverse human 

health effects occur when the risk or rate of exposure to an environmental 

hazard for a minority or low-income population is significant (as 

determined during NEPA analysis) and appreciably exceeds the risk or 

exposure rate for the general population or for another appropriate 

comparison group.

■ Disproportionately High and 

Adverse Environmental Effects

A disproportionately high environmental impact that is significant (as 

defined by NEPA) refers to an impact or risk of an impact on the natural or 

physical environment in a low-income or minority community that 

appreciably exceeds the environmental impact on the larger community. 

Such effects may include ecological, cultural, human health, economic, or 

social impacts. An adverse environmental impact is an impact that is 

determined to be both harmful and significant (as employed by NEPA). In 

the assessment of cultural and aesthetic environmental impacts, impacts 

that uniquely affect geographically dislocated or dispersed minority or lowincome populations or American Indian tribes are considered.
DRAFT Environmental Impacts and Mitigation Measures

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1 socioeconomic, health, and cultural resources to minority and low-income populations (NRC, 

2 2004). 

3 4.12.1 Minority and Low-Income Population Analysis for the Ross Project

4

5 Demographic and socioeconomic data for the Ross Project area and surrounding communities 

6 was assembled to identify minority or low-income populations within a 6-km [4- mi] radius of the 

7 area and is shown in Tables 4.7 and 4.8. 

8

9 Table 4.7 compares race and ethnicity characteristics by census block group to Crook County 

10 and Wyoming. The percentage of the population in Wyoming and Crook County that is 

11 nonwhite is 9.3 percent and 2.9 percent, respectively (100 percent minus percent white alone 

12 equals percent nonwhite). The percentage of nonwhite population that lives in the block groups 

13 within a 6-km [4-mi] radius of the Ross Project area ranges from 0.4 – 2.9 percent. In addition, 

14 the percentage of the population in Wyoming and Crook County who are Hispanic or Latino is 

15 8.9 percent and 2.0 percent, respectively. The percentage of Hispanic or Latino populations 

16 that lives in the block groups within a 6-km [4-mi] radius of the Ross Project area ranges from 

17 1.3 – 4.7 percent. When these numbers are compared to the State and Crook County 

18 proportions, they do not exceed the 20-percent level that is commonly considered of 

19 environmental-justice significance.

20

21 Table 4.8 compares poverty and income characteristics by census tract to Crook County and 

22 Wyoming. The percentage of the population living below poverty for Wyoming and Crook 

23 County as well as Census Tracts 9502 and 9503 are 9.8 percent, 7.8 percent, 7.2 percent, and 

24 9.0 percent, respectively. When these numbers are compared to the State and Crook County 

25 proportions, they also do not exceed the 20-percent level that is considered of environmental26 justice significance.

27 Because no minority or low-income populations, as defined by EO 12898, have been identified 

28 in the Ross Project area, no further environmental-justice analysis (Steps 3 – 5) was conducted.

29

30 4.12.2 Alternative 1: Proposed Action

31

32 Under the Proposed Action, there are no minority or low-income populations identified that are 

33 greater than 20 percent within a 6-km [4-mi] radius of the Proposed Action. Therefore, there are 

34 no disproportionately high and adverse impacts to minority and low-income populations under 

35 the Proposed Action.

36

37 4.12.3 Alternative 2: No Action

38

39 Under the No-Action Alternative, the Ross Project would not be licensed and the land would 

40 continue to be available for other uses. The conditions affecting minority and low-income 

41 populations in the vicinity of the Ross Project area would remain unchanged. Therefore, there 

42 would be no disproportionately high and adverse impacts to minority and low-income 

43 populations under the No-Action Alternative.
4-87

1

Table 4.7

Ross Project Area Race and Ethnicity Characteristics

Area of 

Comparison Total

White 

Alone

%

White 

Alone

Black

or 

African 

American 

Alone

%

Black

or 

African 

American

American 

Indian 

and 

Alaska 

Native 

Alone

% 

American 

Indian 

and 

Alaska 

Native 

Alone

Asian 

Alone

%

Asian 

Alone

Wyoming 563,626 511,279 90.7 4,748 0.8 13,336 2.4 4,426 8.2 

Crook County 7,083 6,884 97.1 14 0.2 48 0.7 11 0.2 

Block Group 1 

Census Tract 9502 1,211 1,176 97.1 0 0 7 0.6 1 0.1 

Block Group 2 

Census Tract 9502 1,880 1,843 98 2 0.1 11 0.6 2 0.1 

Block Group 3 

Census Tract 9502 1,390 1,333 95.9 6 0.4 9 0.6 2 0.1 

Block Group 1 

Census Tract 9503 1,280 1,171 96.9 4 0.3 8 0.7 5 0.4 

Block Group 2 

Census Tract 9503 1,394 1,361 97.6 2 0.1 13 0.9 1 0.1 

Source: USCB, 2012b (P1 and QT-P4). 2
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1

2

Table 4.8

Ross Project Area Poverty and Income Characteristics

Area of Comparisona

Percent Living Below 

Poverty

Median Household 

Income

Wyoming 9.8 $53,802

Crook County 7.8 $49,890

Census Tract 9502 7.2 $52,106

Census Tract 9503 9.0 $46,848

Source: USCB, 2012b.

Notes: 

a = Income data is not available at the Census-Block-Group level for 2010.

b = Source: USCB, 2012b (S1701).

c = Source: USCB, 2012b (B19013)

3

4 4.12.4 Alternative 3: North Ross Project

5

6 Under Alternative 3, the North Ross Project would generally be the same as the Proposed 

7 Action, except that the facility (i.e., the CPP, associated buildings, and auxiliary structures as 

8 well as the surface impoundments) would be located to the north of where it would be located in 

9 the Proposed Action, as described in SEIS Section 2.1.3. As there are no minority or low10 income populations identified that are greater than 20 percent within a 6-km [4-mi] radius of the 

11 Ross Project area under this Alternative, there are no disproportionately high and adverse 

12 impacts to minority and low-income populations. 

13

14 4.13 Public and Occupational Health and Safety

15

16 All phases of the proposed Ross Project could result in potential nonradiological and 

17 radiological impacts to public and occupational health and safety. Impacts to occupational 

18 health and safety could result from both routine exposures to hazardous chemicals and

19 radiation emitted from radionuclides present during uranium-recovery activities, as well as from 

20 exposures following an accident. Public nonradiological impacts are unlikely, except under 

21 accident conditions. Radiological impacts to the public could occur during both routine Ross 

22 Project activities as well as during accidents. 

23 4.13.1 Alternative 1: Proposed Action

24 Alternative 1, the Proposed Action, consists of four phases: construction, operation, aquifer 

25 restoration, and decommissioning of a uranium-recovery facility and wellfields.

26 4.13.1.1 Ross Project Construction

27 Proposed construction activities at the Ross Project are very similar to those described in GEIS 

28 Sections 4.4.1 and 4.4.11, where the greatest risk to a worker is the inhalation of radionuclides 

29 (e.g., radon) during well drilling and installation and inhalation of fugitive dust containing 
DRAFT Environmental Impacts and Mitigation Measures

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1 uranium or its progeny during construction activities. The 10 CFR Part 20 public dose limit is 1 

2 mSv/yr [100 mrem/yr] and the 40 CFR Part 190 annual limit is 0.25 mSv [25 mrem]. The 

3 corresponding occupational dose limit is 50 mSv [5 rem] for total effective dose equivalent

4 (TEDE) exposures. The GEIS states that an internal exposure to radiation via ingestion is 

5 unlikely without substantial intake of the soils and that radiological impacts to both the public 

6 and site workers from inhalation of fugitive dust during construction would be SMALL because 

7 the radionuclide concentrations would be low (NRC, 2009). The GEIS concluded that the 

8 radiological impacts to both the general public as well as construction workers during ISR facility

9 construction would be SMALL. 

10 As described in SEIS Section 2 and consistent with the GEIS, construction activities associated 

11 with the Ross Project would include site preparation and the construction of buildings, storage 

12 ponds, access roads, wellfields, and other structures and systems. The important radiation 

13 exposure pathway during the construction phase would be through direct exposure and 

14 inhalation or ingestion of radionuclides during well construction, construction activities that 

15 disturb surface soil, and fugitive dust from vehicular traffic during construction. However, the 

16 concentrations of these naturally occurring radionuclides are low; for example, the total 

17 concentration of uranium in the native surface soils at the Ross Project area is only 0 to 2.80 

18 mg/kg [2.80 ppm] (on the order of 1 – 2 pCi/g). The low concentrations of radionuclides and the 

19 atmospheric dispersion of radionuclides in fugitive dust would minimize impacts from exposures 

20 to workers. For direct (i.e., gamma) radiation, the public’s potential exposure would be 

21 equivalent to approximately 5.3 to 25.3 microRoentgens (μR) per hour (μR/hr), which is much 

22 lower than the radiation exposure from naturally occurring radionuclides that the public has 

23 during day-to-day activities. Thus, the sparse population near the Ross Project area and its 

24 vicinity, the lack of public access, the low concentrations of radionuclides, and the atmospheric 

25 dispersion of radionuclides in fugitive dust would be sufficient to minimize impacts from any 

26 such exposures to the public. 

27 During the Applicant’s proposed use of mud-rotary drilling techniques during wellfield 

28 installation, some drilling fluids and muds (i.e., cuttings), originating from the ore zone into which 

29 the wells would be drilled, would be brought to the surface. This type of well drilling technique 

30 involves the use of a drilling fluid that is introduced through the drill’s stem, out the drill bit (i.e., 

31 end), and then back up to the surface through the drillhole and the drill stem. These fluids and 

32 muds would be collected in pre-dug pits near the well being installed. After drying out, the pits 

33 would be covered with native topsoil and then re-vegetated (see SEIS Section 2.1.1.5) (Strata, 

34 2011a). However, because these fluids have been passed through the ore-bearing zone, they 

35 have the potential to have higher concentrations of naturally occurring radionuclides than do 

36 surficial soils. As the discussion of the radiological baseline conditions in SEIS Section 3.12.1 

37 establishes, however, the relative concentration of radionuclides would still be small. Thus, the 

38 radiological impacts to the occupational health and safety of workers, including the well-drillers, 

39 would also be SMALL.

40 Construction equipment would likely be diesel powered and would emit diesel exhaust, which 

41 includes small particles (<PM10). The impacts and potential human exposures from these 

42 emissions would be small because the releases are usually short and are readily dispersed into 

43 the atmosphere. SEIS Section 4.7 describes in greater detail the potential impacts to air quality 

44 from proposed diesel emissions including comparisons with health-based standards. Therefore, 

45 the NRC staff concludes that the impact and potential human exposure from these particulate 
DRAFT Environmental Impacts and Mitigation Measures

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1 emissions would be SMALL, consistent with the GEIS conclusions in Section 4.4.11.1 (NRC, 

2 2009).

3 Thus, the potential impacts to public and occupational health and safety during construction of 

4 the Proposed Action are SMALL.

5 4.13.1.2 Ross Project Operation

6 Radiological

7 Normal Conditions

8 As discussed in GEIS Section 4.4.11.2.1, some amount of radioactive materials will be released 

9 to the environment during normal ISR operations. The potential impact from these releases can 

10 be evaluated by the MILDOS-AREA computer code (MILDOS), which Argonne National 

11 Laboratory developed for calculating offsite facility radiation doses to individuals and 

12 populations. MILDOS uses a multi-pathway analysis for determining external dose; inhalation 

13 dose; and dose from ingestion of soil, plants, meat, milk, aquatic foods, and water. The primary 

14 radionuclide of interest at an ISR facility is radon-222. MILDOS uses a sector-average 

15 Gaussian plume dispersion model to estimate 

16 downwind concentrations. This model typically 

17 assumes minimal dilution and provides 

18 conservative estimates of downwind air 

19 concentrations and doses to human receptors.

20 GEIS Section 4.4.11.2.1 presented historical 

21 data for ISR operations, providing a range of 

22 estimated offsite doses associated with six 

23 current or former ISR facilities. For these 

24 operations, doses to potential offsite exposure 

25 (human receptor) locations range between 0.004 

26 mSv [0.4 mrem] per year for the Crow Butte 

27 facility in Nebraska and 0.32 mSv [32 mrem] per 

28 year for the Irigaray facility in Johnson County, 

29 Wyoming. In each case, the estimated dose is 

30 well below the 10 CFR Part 20 annual radiation 

31 public dose limit of 1 mSv/yr [100 mrem/yr] (NRC, 2009).

32 GEIS Section 4.4.11.2.1 also provided a summary of doses to occupationally exposed workers 

33 at ISR facilities. As stated, estimated doses at an ISR facility are not dependent on a facility’s 

34 location and are well within the 10 CFR Part 20 annual occupational dose limit of 0.05 Sv [5 

35 rem] per year. The largest annual average dose to a worker at a uranium recovery facility over a 

36 10-year period [1994–2006] was 0.007 Sv [0.7 rem]. More recently, the maximum total dose 

37 equivalents reported for 2005 and 2006 were 0.00675 and 0.00713 Sv [0.675 and 0.713 rem]. 

38 Similarly, the average and maximum worker exposure to radon and radon daughter products 

39 ranged from 2.5 to 16 percent of the occupational exposure limit of 4 working-level months. 

40 NRC staff concluded in the GEIS that the radiological impacts to workers during normal 

41 operations at ISR facilities will be SMALL.

How is radiation measured?

Radiation dose is measured in units of 

either Sievert or rem and is often referred 

to in either milliSv/mSv or millirem/mrem 

where 1,000 mSv = 1 Sv and 1,000 mrem 

= 1 rem. The conversion for Sieverts to 

rem is Sv=100 rem. These units are used 

in radiation protection to measure the 

amount of damage to human tissue from a 

dose of ionizing radiation. Total effective 

dose equivalent, or TEDE, refers to the 

sum of the deep-dose equivalent (for 

external exposures) and the committed 

effective dose equivalent (for internal 

exposures).
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1 For occupational doses at the proposed Ross Project, the planned ISR facility design and 

2 operations are consistent with those analyzed in the GEIS. To mitigate radiological exposure to 

3 workers, the applicant will (i) install ventilation designed to limit worker exposure to radon; (ii) 

4 install gamma exposure rate monitors, air particulate monitors, and radon daughter product 

5 monitors to verify that expected radiation levels are met; and (iii) conduct work area radiation 

6 and contamination surveys to help prevent and limit the spread of contamination (Strata, 

7 2011a). The applicant’s airborne radiation monitoring program is further described in SEIS 

8 Section 6.

9 For estimated maximum dose to members of the public, GEIS Section 4.4.11.1.2 noted that 

10 radon gas is emitted from ISR wellfields and processing facilities during operations and is the 

11 only radiological airborne effluent during normal operations for facilities using vacuum dryer 

12 technology (NRC, 2009). The Applicant plans to dry yellowcake using a rotary vacuum dryer 

13 (Strata, 2011a). Therefore, during normal operations, emissions other than radon are not 

14 expected.

15 The Applicant evaluated the potential consequences of radiological emissions at the proposed 

16 Ross Project (Strata, 2011a). Sources of radon emanation the Applicant identified and modeled 

17 consisted of point sources (i.e., those operations that have their exhaust confined in a stack, 

18 duct, pipe, etc., prior to atmospheric release, such as process tank vents) and area sources 

19 (i.e., ore pads and wellfields). The Applicant described its implementation of the computer code 

20 MILDOS that was used to model radiological impacts on human and environmental receptors 

21 (e.g., air and soil) using site-specific data that included Rn-222 release estimates, 

22 meteorological and population data, and other parameters. The estimated radiological impacts 

23 from routine site activities were compared to applicable public dose limits in 10 CFR Part 20 {1 

24 mSv/yr [100 mrem/yr]}, as well as to baseline radiological conditions (see SEIS Section 3).

25 The NRC review of the Applicant’s radiological impact modeling independently verified that 

26 appropriate exposure pathways were modeled and reasonable input parameters were used.

27 The Applicant also listed the origin of the input parameters and provided justification for their 

28 use. The Applicant described the source terms, and the NRC staff review concluded that the 

29 source terms represented operations at full capacity and consisted of ISR operations at the 

30 wellfields and releases from the CPP and deep disposal wells. The Applicant calculated the 

31 TEDE across the projected area on a grid system centered about the CPP and extending 

32 beyond the site boundary for a total of 287 locations, 14 members of the public including 

33 children that could be living at the four nearest residences and the Oshoto Field Office, 5 

34 ranchers, 2 oil-field workers, and 2 vendors/couriers working both within and outside of the 

35 project area.

36 Results of the Applicant’s modeling indicate that the maximum TEDE of 0.016 mSv/yr [1.6 

37 mrem/yr] is located near the Ross Project boundary in the vicinity of the CPP area. The 

38 Applicant’s calculations also demonstrate that inhalation accounted for 98 percent of the TEDE 

39 at this location (Strata. 2011a). Thus, the 10 CFR Part 20 public dose limit is not expected to be 

40 exceeded at any property boundary. The annual background dose to the population within 80 

41 km of the Ross Project is estimated at 10,500 person-rem based on a background radiation 

42 dose of 2.57 mSv/yr for Wyoming. For comparison, the TEDE from the Ross Project to the 

43 population based on the Applicant’s modeling is estimated to be 0.361 person-rem. This TEDE 

44 represents 1.6 percent of the 10 CFR Part 20 public dose limit of 1 mSv/yr [100 mrem/yr].
DRAFT Environmental Impacts and Mitigation Measures

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1 Because Rn-222 is the only radionuclide emitted during normal operations, the public dose 

2 requirements in 40 CFR Part 190 and the 0.1 mSv/yr [10 mrem/yr] constraint rule in 10 CFR 

3 Part 20.1101 do not apply. The Applicant calculated that radon emissions from the wellfields 

4 accounted for 75 percent of the total emissions. In its calculations, the Applicant assumed that 

5 100 percent of the radon in the liquids was released to the atmosphere. The estimated radon 

6 release from the facility is listed in Table 7.3-4 of the application (Strata, 2011a). The dose to 

7 the public is below the 10 CFR Part 20 public dose limit, thus, radiological dose impacts to the 

8 public from normal operations will be SMALL.

9 In summary, potential radiation doses to occupationally exposed workers and members of the 

10 public during normal operations would be SMALL. Calculated radiation doses from the releases 

11 of radioactive materials to the environment are small fractions of the limits in 10 CFR Part 20 

12 that have been established for the protection of public health and safety. In addition, the 

13 applicant is required to implement an NRC-approved radiation protection program (RPP) to 

14 protect occupational workers and ensure that radiological doses are as low as reasonably 

15 achievable (ALARA). The applicant’s RPP includes commitments for implementing 

16 management controls, engineering controls, radiation safety training, radon monitoring and 

17 sampling, and audit programs (Strata, 2011a). 

18 Accident Conditions

19 The GEIS identified, discussed, and assessed the consequences for bounding abnormal and 

20 accident conditions that might occur with an ISR operation. The GEIS information was based 

21 on previous radiological hazard assessments (Mackin, et al., 2001) that considered the various 

22 stages of an ISR facility. The GEIS considered three separate accidents, which represent 

23 events resulting in higher levels of radioactivity being released: thickener failure and spill, 

24 pregnant lixiviant and loaded resin spills (radon release), and yellowcake dryer accident release. 

25 The GEIS concluded that potential impacts to workers could be MODERATE based on the 

26 estimated consequences of an unmitigated dryer release, but doses to the general public would 

27 be SMALL.

28 An overview of these three accident scenarios, as evaluated in the GEIS along with a specific 

29 application to the Ross Project, is presented in the following paragraphs.

30 Thickener Failure and Spill

31 Thickeners are used to concentrate yellowcake slurry before it is transferred to a dryer or 

32 packaged for offsite shipment. Radionuclides could be inadvertently released to the 

33 atmosphere through thickener failure or spill. This accident scenario, as evaluated in the GEIS, 

34 assumed a tank or pipe leak that releases 20 percent of the thickener inside and outside of the 

35 processing building. The analyses included a variety of wind speeds, stability classes, release 

36 durations, and receptor distances. A minimum receptor distance of 500 m [1,640 ft] was 

37 selected because it was found to be the shortest distance between a processing facility and an 

38 urban development for currently operating ISR facilities. Offsite, unrestricted doses from such a 

39 spill could result in a dose of 0.25 mSv [25 mrem], or 25 percent of the annual public dose limit 

40 of 1 mSv [100 mrem] per year with negligible external doses based on sufficient distance 

41 between facility and receptor (NRC, 2009). The nearest two residences to the Ross Project 

42 facility are located at a distance of 800 m [2,500 ft] and 1,700 m [5,600 ft], which are further than 

43 the minimum distance analyzed in the GEIS. Therefore, the potential public dose from a 

44 thickener spill at the Ross Project would be less than the dose estimated in the GEIS.
DRAFT Environmental Impacts and Mitigation Measures

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1 As stated in the GEIS, doses to unprotected workers inside the facility have the potential to 

2 exceed the annual dose limit of 0.05 Sv [5 rem] if timely corrective measures are not taken to 

3 remediate the spill. Typical protection measures such as monitoring, respiratory protection, and 

4 radioactive material control, which would be a part of the applicant’s radiation protection 

5 program, would reduce worker exposures and resulting doses to a small fraction of those 

6 evaluated (NRC, 2009). The Applicant has proposed a radiation protection program and a spill 

7 response program that would include similar commitments to those described in the GEIS, such 

8 as requiring the use of personal protective equipment (PPE) (Strata, 2011a). Therefore, the 

9 potential dose to workers at the Ross Project from a thickener spill is expected to be consistent 

10 with the dose estimate provided in the GEIS but this dose would be reduced significantly, as 

11 described in the GEIS, by the Applicant’s implementation of radiation protection and spill 

12 response programs.

13 Pregnant Lixiviant and Loaded Resin Spills

14 Process equipment (e.g., ion-exchange columns) at the Ross Project would be located on 

15 curbed concrete pads to prevent any liquids from spills or leaks from exiting the building and 

16 contaminating the outside environment of the facility. In the event of a process tank failure, 

17 released fluids would be captured in concrete berms in the process building, which would be 

18 designed to contain a volume of 110 percent of the largest tank in the building (Strata, 2011b). 

19 Collected fluids would be pumped via a sump to other process vessels, a lined surface 

20 impoundment, or a deep disposal well and the contaminated area would be washed down. 

21 Additionally, personnel would follow spill response procedures, which would require the use of 

22 PPE (Strata, 2011a). Therefore, except for wellfield leaks, the NRC staff does not consider an 

23 accidental liquid release with liquid pathways of exposure to be realistic. The primary radiation 

24 source for liquid releases within the Ross Project facility would be the resulting airborne radon25 222 released from a liquid or resin tank spill.

26 In the case of a wellfield leak at the Ross Project, pregnant lixiviant could be released from the 

27 pipes containing the fluid onto the soil below. The Applicant would be able to identify such a 

28 leak by monitoring the pipelines to detect changes in pressure or flow. If a significant change in 

29 pressure or flow is detected, an alarm would sound at the CPP, which would prompt the 

30 Applicant’s personnel to investigate the cause and identify any leaks. If the pressure or flow 

31 change is outside of acceptable operating parameters, the pumping system would automatically 

32 shut down. Additionally, wellfield operators would visually inspect all piping and equipment 

33 within the module buildings, wellheads, and valve vaults at least weekly (Strata, 2011a). 

34 Potentially contaminated soil will be sampled and contaminated soil would be removed and 

35 disposed of in accordance with NRC and State requirements. In the event of a spill that meets 

36 NRC criteria for reporting, the Applicant will notify the NRC within 24 hours and submit a report 

37 within 30 days that describes the conditions leading to the spill, the corrective actions taken, and 

38 the results achieved.

39 The GEIS assumed a radon accident release scenario in which a pipe or valve of the ion40 exchange system, containing pregnant lixiviant, develops a leak and releases (almost 

instantaneously) all the radon-222 at a high activity level (2.96 x 107 Bq/m3 [8 x 105 41 pCi/L]). For

42 a 30-minute exposure, the dose to a worker located inside the building performing light activities 

43 without respiratory protection was estimated as 10 mSv [1,300 mrem], which is below the 10 

44 CFR Part 20 occupational dose limits (NRC, 2009). The Ross Project would include a piping 

45 system containing pregnant lixiviant consistent with the system evaluated in the GEIS and, 
DRAFT Environmental Impacts and Mitigation Measures

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1 therefore, the potential dose estimated in the GEIS is consistent with the dose expected during 

2 this type of accident scenario at the Ross Project. Ventilation systems and alarms at the Ross 

3 Project that would alert workers to immediately evacuate the building would further reduce the 

4 potential exposure and resulting dose to workers. Considering that atmospheric transport offsite 

5 would reduce the airborne levels by several orders of magnitude, any dose to a member of the 

6 public would be less than the 1 mSv [100 mrem] public dose limit of 10 CFR Part 20. 

7 Yellowcake Dryer Accident Release

8 In GEIS Section 4.4.11.2.2, the consequences of an explosion involving a multiple-hearth 

9 yellowcake dryer at an ISR facility were evaluated. The analysis assumes that about 4,409 kg 

10 [9,500 lb] of uranium yellowcake is released within the building housing the dryer and that, due 

11 to the nature of the material, most of the yellowcake would rapidly fall out of airborne 

12 suspension. Therefore, only 1 kg [2.2 lb] of the yellowcake is assumed to be subsequently 

13 released as an airborne effluent to the outside atmosphere as a 100 percent respirable powder. 

14 The calculated maximum dose to workers in this scenario would be 0.088 Sv [8.8 rem], which 

15 exceeds the annual occupational dose limit of 0.05 Sv [5 rem] established in 10 CFR Part 20. 

16 The atmospheric dispersion of the fraction of the yellowcake that is assumed to be released as 

17 an airborne effluent would significantly reduce the exposure to members of the public to about 

18 6.5 x 10-4 Sv [65 mrem], which is less than the 10 CFR Part 20 public dose limit of 1 mSv [100 

19 mrem] (NRC, 1980).

20 The Applicant proposes to use a vacuum dryer for both yellowcake and vanadium, which is the 

21 current industry standard for ISR facilities. In a vacuum dryer, the heater combustion source is 

22 separated from the dryer itself. This configuration mostly eliminates the possibility of an 

23 explosion, which is the initiating event for the accident scenario considered in the GEIS. 

24 Therefore, the vacuum dryer accident release that could occur at the Ross Project is expected 

25 to have less significant consequences than the multiple-hearth yellowcake dryer accident 

26 release scenario considered in the GEIS. The Applicant analyzed the potential for a release of 

27 yellowcake from a vacuum dryer into the dryer room due to a seal rupture. Operating 

28 procedures proposed by the Applicant such as conducting regular inspections of the seals and 

29 monitoring for pressure changes and other indicators of problems with the seal during dryer 

30 operations would reduce the likelihood of an unnoticed seal rupture. However, in the event of a 

31 yellowcake release due to a seal rupture, dose to workers would be minimized because they 

32 would be required to wear respiratory protection when the dryer is in operation and would 

33 immediately evacuate the area. Public exposure would be significantly reduced, as described in 

34 the GEIS, due to atmospheric dispersion of any fraction of the yellowcake that is released from 

35 the dryer building.

36 Accident Analysis Conclusions 

37 The NRC staff reviewed and evaluated site-specific and project-specific information related to 

38 potential accidents and determined that the types of accidents analyzed in the GEIS and their 

39 potential consequences bound those that could occur for the proposed Ross Project. There 

40 would be no significant radiological impacts from potential accidents to the public or 

41 occupationally exposed workers beyond those described in the GEIS. Based on this finding, the 

42 potential doses may result in a MODERATE impact to occupational health and safety, in the 

43 case of an unmitigated accident, and a SMALL impact to public health and safety. Occupational 

44 health and safety impacts from accidents would be reduced by the Applicant implementing 
DRAFT Environmental Impacts and Mitigation Measures

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1 protection measures such as routine monitoring, spill response and cleanup procedures, and 

2 respiratory protection. Therefore, the overall radiological impacts to public and occupational 

3 health and safety from accidents during operations would be SMALL.

4 Nonradiological 

5 Normal Conditions

6 GEIS Section 4.4.11.2.4 identified the various chemicals, hazardous and nonhazardous, that 

7 are typically used at ISR facilities. The GEIS also identifies the typical quantities of these 

8 chemicals that are used. The following hazardous chemicals would be used in the largest 

9 quantities at the CPP during the Ross Project’s operation:

10 ■ Anhydrous ammonia

11 ■ Sodium hydroxide

12 ■ Sulfuric acid and/or hydrochloric acid

13 ■ Oxygen

14 ■ Hydrogen peroxide

15 ■ Carbon dioxide

16 ■ Sodium carbonate

17 ■ Sodium chloride

18 ■ Ammonium sulfate

19

20 Each of these chemicals would be purchased in bulk, would be transported to the Project area 

21 by motorized vehicles, and would be stored within the controlled area of the Ross Project (i.e., 

22 in the fenced facility itself). Typical onsite quantities for some of these chemicals exceed the 

23 regulated, minimum reporting quantities and trigger an increased level of regulatory oversight 

24 regarding possession (type and quantities), storage, use, and disposal practices. The use of 

25 hazardous chemicals at ISR facilities is controlled under several regulations that are designed to 

26 provide adequate protection to workers and the public. The primary regulations applicable to 

27 use and storage include the following:

28 ■ 40 CFR Part 68: Chemical Accident Prevention Provisions. This regulation lists 

29 regulated toxic substances and threshold quantities for accidental-release prevention.

30 ■ 29 CFR Part 1910.119: Occupational Safety and Health Administration 

31 Standards/Process Safety Management of Highly Hazardous Chemicals. This 

32 regulation lists highly hazardous chemicals as well as toxic and reactive substances (i.e., 

33 chemicals that can potentially cause a catastrophic event at or above the threshold 

34 quantity).

35 ■ 29 CFR Part 1910.120: Hazardous Waste Operations and Emergency Response. This 

36 regulation instructs employers to develop and implement a written health and safety 

37 program for their employees involved in hazardous-waste operations. The program should 
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1 be designed to identify, evaluate, and control health and safety hazards and provide for 

2 emergency response during hazardous-waste operations.

3 ■ 40 CFR Part 355: Emergency Planning and Notification. This regulation lists extremely 

4 hazardous substances and their threshold planning quantities so that emergency response 

5 plans can be developed and implemented. There are approximately 360 extremely 

6 hazardous substances listed. Over a third of these are defined by the Comprehensive 

7 Environmental Response, Compensation, and Liability Act (CERCLA), the “Superfund” law. 

8 The regulations associated with this statute also list so-called “reportable quantity” values for 

9 these substances. 

10 ■ 40 CFR Part 302.4: Designation, Reportable Quantities, and Notification/Designation 

11 of Hazardous Substances. This regulation identifies the reportable quantities for the 

12 CERCLA hazardous substances on the promulgated list. There are approximately 800 of 

13 these substances, and they are compiled from the 1) CWA, Sections 311 and 307(a); 2) 

14 CAA, Section 112; 3) Resource Conservation and Recovery Act [RCRA], Section 3001; and 

15 4) Toxic Substance Control Act, Section 7.

16

17 The Applicant’s compliance with applicable regulations would reduce the likelihood of continuing 

18 or significant releases, which may result in injury or illness to an exposed worker. The risk of 

19 offsite impacts to the public due to a chemical spill is not significant because chemicals would 

20 be stored and used in or near the facility and wellfields. Therefore, impacts to the public would 

21 be SMALL.

22 To promote occupational health and safety, the Applicant would issue a formal Safety Policy 

23 Statement to define its overall health- and safety-protection policy and the requirements that 

24 must be met by all employees and contractors at all times while at the Ross Project (Strata, 

25 2012a). In addition, the Applicant proposes the development of several plans, SOPs, and other 

26 management tools to further decrease and mitigate occupational health and safety impacts 

27 (Strata, 2011a). All workers and contractors would receive required health and safety training. 

28 This training would include indoctrination to plans such as the Project’s HASP, as well as all 

29 pertinent SOPs and BMPs. The Ross Project would operate under a comprehensive Project 

30 HASP, which would include specific industrial-hygiene SOPs and other health and safety plans. 

31 These SOPs would govern a worker entering a confined space, trenching and excavation of 

32 utility and pipeline corridors, referring to appropriate Material Safety Data Sheets (MSDSs), 

33 decanting a hazardous chemical, and donning appropriate levels of PPE. Other health and 

34 safety plans could include a respiratory protection plan, a hearing conservation plan, and a 

35 health and safety training plan. These latter plans would be developed and instituted by the 

36 Applicant only when it is not practical to use process or other engineering controls [Strata, 

37 2012a]). The Applicant’s HASP would also include specific training requirements and hazard 

38 identification and mitigation policies and procedures. The HASP would define the protocols, 

39 methods, and procedures the Applicant would use to ensure compliance with the OSHA 

40 requirements found at 29 CFR Part 1910.

41 The types and quantities of chemicals (hazardous and nonhazardous) identified for use at the 

42 proposed Ross Project are consistent with those evaluated in the GEIS. Additionally, the 

43 Applicant proposes to implement the occupational health and safety protection plans evaluated 

44 for typical ISR facilities in the GEIS and to comply with the requirements of regulations 

45 governing the use and storage of chemicals. Therefore, the NRC staff concludes that the 
DRAFT Environmental Impacts and Mitigation Measures

4-97

1 nonradiological impacts to public and occupational health and safety during normal operations 

2 of the Proposed Action would be SMALL.

3 Accident Conditions

4 Potential nonradiological accidents are consistent with the typical accidents at other industrial 

5 facilities, including high consequence chemical release events. In GEIS Section 4.4.11.2.2, the 

6 likelihood of such a release is determined to be low based on historical operating experience at 

7 ISR facilities, primarily due to operators following commonly applied chemical safety and 

8 handling protocols. Past history at current and former ISR facilities demonstrates that these 

9 facilities can be designed and operated with measures that adequately reduce the risks to 

10 worker and public health and safety. The GEIS concluded that the nonradiological impacts due 

11 to accidents at an ISR facility would be SMALL offsite and potentially MODERATE for workers 

12 involved in accident response and cleanup.

13 If a large quantity of one or more of the chemicals that would be present in significant quantities 

14 at the Ross Project were to be released during the Ross Project’s operation, the nonradiological 

15 impacts to public health and safety would depend on the proximity of potentially impacted 

16 populations. Potential receptors are sparse in the area around the Ross Project (the nearest 

17 residents to the Ross Project are identified in Figure 3.1 in SEIS Section 3.2). In addition, the 

18 Ross Project area is large and affords distance that would allow released hazardous chemicals 

19 to be either deposited or dispersed before reaching the Project boundaries, thereby diminishing 

20 individual impacts. Workers involved in a response and cleanup of an accident could 

21 experience MODERATE impacts, but training requirements and the establishment of and 

22 adherence to applicable procedures would reduce the impact to SMALL. Thus, consistent with 

23 the GEIS, impacts to public and occupational health and safety due to an onsite accident during 

24 Ross Project operations would be SMALL.

25 4.13.1.3 Ross Project Aquifer Restoration

26 GEIS Section 4.4.11 indicated that the activities that would take place during aquifer restoration 

27 are similar to ISR facility operation (i.e., wellfield operation, uranium extraction, waste-water 

28 treatment, and waste disposal), except that each would begin to diminish as less and less 

29 uranium is recovered from the production aquifer. The gradual cessation of many of these 

30 processes as the Ross Project, such as loaded-IX-resin elution, yellowcake drying and 

31 packaging, vanadium recovery and packaging, further limits the relative magnitude of potential 

32 public and occupational health and safety hazards. There would be fewer opportunities for 

33 accidents with the decreasing number of operations and the decreasing workforce as well as 

34 fewer chemicals used onsite and smaller volumes of chemicals stored onsite. The same 

35 mitigation measures and management controls, such as the RPP and the Project’s HASP, as 

36 discussed earlier for the Ross Project’s construction and operation would be observed during its 

37 aquifer-restoration phase. Thus, the nonradiological and radiological impacts to public and 

38 occupational health and safety during aquifer restoration would be SMALL.

39 4.13.1.4 Ross Project Decommissioning

40 The GEIS found in Section 4.4.11 (NRC, 2009) that the radiological impacts to the public and 

41 occupational health and safety from the decommissioning of an ISR project would be SMALL. 

42 Consistent with the description in the GEIS, the magnitudes of potential impacts from the 

43 decommissioning of the Ross Project facility and its wellfields would be less significant than
DRAFT Environmental Impacts and Mitigation Measures

4-98

1 impacts during operations because hazards would be reduced and eliminated; and soils, 

2 structures, and equipment would be decontaminated. 

3 In addition to the mitigation measures described in SEIS Section 4.13.1.1, the NRC would 

4 require that the Applicant submit a decommissioning plan for the Ross Project for its review and 

5 approval. Protection of workers and the public is ensured through NRC approval of the 

6 decommissioning plan and verification that doses from exposures during decommissioning 

7 would comply with 10 CFR Part 20 limits. Following decommissioning, the Ross Project site 

8 could be released for unrestricted use in conformance with the conditions of the NRC license 

9 and the dose criteria for site release in 10 CFR Part 40, Appendix A. The criteria in 10 CFR 

10 Part 40, Appendix A limit the dose from radiological contamination that may exist at the site after 

11 decommissioning is complete to levels that are sufficiently low to protect public health and 

12 safety. Therefore, the impacts to public and occupational health and safety from the 

13 decommissioning of the Ross Project would be SMALL.

14 4.13.2 Alternative 2: No Action

15 Under the No-Action Alternative, the Ross Project would not be licensed and the land would 

16 continue to be available for other uses. However, until the NRC has made its decision 

17 regarding the licensing of the Project, the Applicant could continue with some of preconstruction 

18 activities (e.g., monitoring well installation). In addition, if the NRC license is not issued, there 

19 would need to be some additional work to properly abandon the wells that would have been 

20 installed by the Applicant. However, the public and occupational impacts to health and safety of 

21 this No-Action Alternative would be less than those impacts associated with the construction of 

22 the Proposed Action (i.e., Alternative 1). Thus, the public and occupational impacts of the No23 Action Alternative would be SMALL. 

24 4.13.3 Alternative 3: North Ross Project 

25 Under Alternative 3, the North Ross Project would generally be the same as the Proposed 

26 Action, except that the facility (i.e., the CPP, associated buildings, and auxiliary structures as 

27 well as the surface impoundments) would be located to the north of where it would be located in 

28 the Proposed Action and the construction of a CBW would not be necessary, as described in 

29 SEIS Section 2.1.3. 

30 Under Alternative 3, the length of the wellfield pipelines may be increased and, thus, there 

31 would be more pipeline subject to failure. However, the Applicant would implement the same 

32 procedures described under the Proposed Action to reduce the risk and severity of pipeline 

33 failures (e.g. monitoring the pipelines to detect changes in pressure or flow, allowing for 

34 automatic shut down of the pumping system, visually inspecting piping at least weekly, and 

35 removing contaminated soil). 

36 Alternative 3 would be located, constructed, and operated farther away from the primary roads 

37 to the Ross Project area, which would require the construction of additional road extensions. 

38 This road construction would generate additional fugitive dust. However, the nearest residential 

39 receptors would be farther away from the CPP under the North Ross Project than they would be 

40 from the location of the CPP under the Proposed Action; thus, they would be less affected 

41 overall by fugitive dust and/or the impacts of accidents. Construction activities and chemical 

42 use would be similar to the Proposed Action because the construction footprint of the facility 

43 would be consistent with the Proposed Action. Construction activities associated with 
DRAFT Environmental Impacts and Mitigation Measures

4-99

1 constructing and decommissioning the CBW with the Proposed Action and the associated 

2 incremental contribution to public and occupational health and safety would not be present

3 under Alternative 3. All other potential public and occupational health impacts would be the 

4 same as described for the Ross Project in this SEIS Section 4.13.1. Consequently, as with the 

5 Proposed Action, workers involved in a response and cleanup of an accident could experience 

6 MODERATE impacts, but training requirements and the establishment of and adherence to 

7 applicable procedures would reduce the impact to SMALL. Thus, the impacts to public and 

8 occupational health and safety of Alternative 3 would be SMALL.

9 4.14 Waste Management

10

11 The Proposed Action could have potential waste-management impacts during all phases of its 

12 lifecycle. Waste volumes, disposal practices, and associated mitigation measures for the four 

13 phases of the Proposed Action are evaluated and compared to the impacts identified in the 

14 GEIS (NRC, 2009). The waste management practices, waste types, and estimated waste 

15 volumes that the Applicant proposes are generally consistent with the typical ISR facility 

16 described in the GEIS. The impacts of the Applicant’s management of liquid and solid waste 

17 streams for each phase of the Proposed Action as well as the two Alternatives are evaluated in 

18 this section. All of the three Alternatives are described in SEIS Section 2.1; impacts from the 

19 transportation of solid wastes offsite for disposal are evaluated in SEIS Section 4.3.1; impacts to 

20 the geology, soils, and water resources as a result of spills, leaks, and other accidental releases 

21 of liquid wastes as well as onsite disposal of liquid wastes are assessed in SEIS Sections 4.3.1 

22 and 4.4.1, respectively.

23

24 4.14.1 Alternative 1: Proposed Action

25

26 Alternative 1, the Proposed Action, consists of four phases: construction, operation, aquifer 

27 restoration, and decommissioning of a uranium-recovery facility and wellfields.

28

29 The volumes of each type of waste the Applicant expects to be generated by the Ross Project 

30 and the Applicant’s proposed management approach and disposal activities are fully described 

31 in SEIS Section 2.1.1 and are shown in Table 4.9. As described, the specific permits that the 

32 Applicant would need to obtain for its UIC Class I deep-injection wells would mitigate many of 

33 the impacts of liquid-waste disposal at the Project. The pre-operational agreements with solid34 waste and radioactive-waste disposal facilities that are required to be in place prior to the NRC’s 

35 issuing a license to the Applicant would mitigate impacts from solid-waste management (NRC, 

36 2009). As part of these agreements, the Applicant would need to ensure that sufficient capacity 

37 for solid byproduct wastes (liquid byproduct wastes would be disposed of onsite in the deep38 injection Class I UIC wells) would be available throughout the lifecycle of the Ross Project 

39 (NRC, 2009). NRC license conditions and inspections would ensure that proper practices are 

40 used by the Applicant to comply with safety requirements to protect workers and the public 

41 during waste management (NRC, 2009). The Applicant would implement waste-minimization 

42 and volume-reduction BMPs, as possible, to further mitigate the impacts of waste management 

43 (Strata, 2011a). 

44

45 Each of the disposal facilities noted in Table 4.9 has indicated to the Applicant that it has 

46 sufficient disposal capacity to accept the volumes of wastes shown in Table 4.9 (see Table ER 

47 RAI Waste-1-1 in Strata, 2012a).
DRAFT Environmental Impacts and Mitigation Measures

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1

Table 4.9

Ross Project Waste Streams

Waste Stream Source Disposal Method

Estimated 

Typical Quality

NRC-Regulated Wastes

Excess Permeate Uranium Production

Aquifer Restoration

RO Circuits

Reinjection into Wellfield

CPP Make-Up Water

Deep-Well Injection

C: 0 m3/min [0 gal/min]

O: 0.2 m3/min [57 gall/min]

R: 0 m3

/min [0 gal/min]

D: 0 m3

/min [0 gal/min]

Brine and Other Liquid 

Byproduct Wastes

Uranium Production

Aquifer Restoration

RO Circuits

Spent Eluate

Process Drains

Contaminated Reagents

Filter Backwash

Wash-Down Water

Decontamination Showers

Deep-Well Injection

Evaporation from Surface

 Impoundments

C: 0 m3/min [0 gal/min]

O: 0.2 m3/min [62 gal/min]

R: 0.9 m3

/min [227 gal/min]

D: 0.04 m3

/min [<10 gal/min]

Solid Byproduct Wastes Filtrate and Spent Filters

Scale and Sludges from

 Equipment Maintenance

Contaminated Soils

Damaged IX Resins

Contaminated Solids

 from Wells

Contaminated PPE

Contaminated Materials

 and Equipment

Shipment to NRC- or 

 Agreement State-

 Licensed Disposal Facility

C: 0 m3 [0 yd3]

O: 76 m3/yr [100 yd3/yr]

R: 76 m3

/yr [100 yd3/yr]

D: 3,058 m3 [4,000 yd3

]

Non-NRC-Regulated Wastes

TENORM Drilling Fluids and Muds Mud Pits C: Per Well = 

Drilling Fluids 

23 m3 [6,000 gal]

Drilling Muds 

0.1 m3 [15 yd3

]

O: 0 m3 [0 gal]

R: 0 m3 [0 gal]

D: 0 m3 [0 gal]

Industrial or Municipal Solid 

Waste

General Office Trash Shipment to Municipal 

 Landfill

C: 11 m3/wk [15 yd3/wk]

O: 11 m3

/wk [15 yd3/wk]

R: 11 m3

/wk [15 yd3/wk]

D: 11 m3

/wk [15 yd3/wk]

Recyclable Solid Waste Plastic, Glass, Paper, 

 Aluminum, and 

 Cardboard

Shipment to Municipal 

 Recycling Facility

Recyclable Waste-

 Collection Facility

C: 4 m3/wk [5 yd3/wk]

O: 4 m3/wk [5 yd3/wk]

R: 4 m3

/wk [5 yd3/wk]

D: 4 m3

/wk [5 yd3/wk]

2
DRAFT Environmental Impacts and Mitigation Measures

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Table 4.9

Ross Project Waste Streams

(Continued)

Waste Stream Source Disposal Method

Estimated 

Typical Quality

Construction and Demolition 

Debris

Construction Debris

Decontaminated Materials

 and Equipment

Shipment to Demolition-

 Debris Landfill

C: 4 m3/wk [5 yd3/wk]

O: 4 m3/wk [5 yd3/wk]

R: 4 m3

/wk [5 yd3/wk]

D: 1,529 m3 [2,000 15 yd3

]

Petroleum-Contaminated 

Soil

Equipment Spills and 

 Leaks

Shipment to 

 WDEQ/SHWD-

 Permitted 

 Disposal Facility

C: < 0.8 m3/mo [< 1 yd3/wk]

O: < 0.8 m3/mo [< 1 yd3/wk]

R: < 0.8 m3

/mo [< 1 yd3/wk]

D: < 0.8 m3

/mo [< 1 yd3/wk]

Hazardous Waste Used Batteries

Expired Laboratory 

 Reagents

Fluorescent Bulbs

Solvents, Cleaners, and

 Degreasers

Shipment to 

 WDEQ/SHWD-

 Permitted 

 Recycling or Disposal 

 Facility

C, O, R, D: 

< 100 kg/mo [< 220 lb/mo]

Used Oil Vehicle Maintenance Shipment to Used-Oil 

 Recycling Facility

C: 0.02 m3/mo [5 gal/mo]

O: 0.02 m3

/mo [5 gal/mo]

R: 0.02 m3/mo [5 gal/mo]

D: 0.02 m3

/mo [5 gal/mo]

Used Oil Filters 

and Oily Rags

Vehicle and Equipment

 Maintenance

Shipment to Used-Oil 

 Recycling Facility

C: < 9 m3 [< 20 lb/mo]

O: < 9 m3 [< 20 lb/mo]

R: < 9 m3 [< 20 lb/mo]

D: < 9 m3 [< 20 lb/mo]

Domestic Sewage Restrooms Onsite Waste-Water 

 Disposal or Treatment 

 System 

Holding Tanks/Portable 

 Toilets during 

 Construction and 

 Decommissioning

C: 9.8 m3/d [2,600 gal/d]

O: 3 m3/d [800 gal/d]

R: 1.1 m3

/d [300 gal/d]

D: 4.5 m3

/d [1,200 gal/d]

Source: Strata, 2012a.

Notes:

C = Construction

O = Operation

R = Aquifer Restoration

D = Decommissioning

1

2 4.14.1.1 Ross Project Construction

3

4 As described in GEIS Section 4.4.12, construction activities would be expected to generate low 

5 volumes of wastes. No radioactive wastes that are regulated by the NRC would be generated 

6 during the Proposed Action’s construction phase. The GEIS found that the waste management 

7 impacts from the construction of an ISR facility would be SMALL due to the limited volumes of 

8 wastes (NRC, 2009).

9
DRAFT Environmental Impacts and Mitigation Measures

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1 Liquid Waste

2

3 Non-byproduct liquid waste would be generated during construction of the Ross Project from the 

4 Applicant’s drilling and development of injection, recovery, and monitoring wells. Construction 

5 of the Class I deep-injection wells would produce drilling fluids and muds. The Applicant

estimates that a volume of 22,000 L [6,000 gal] of water and 12 m3 [15 yd3 6 ] of drilling muds 

7 would be produced per well (Strata, 2012a). These fluids would be stored onsite in mud pits 

8 which would be constructed adjacent to the respective drilling pad(s) and evaporated. The 

9 GEIS found that the liquid waste management impacts from the construction of an ISR facility 

10 would be SMALL due to the limited volumes of wastes (NRC, 2009).

11

12 Construction releases from the mud pits would be mitigated by the implementation of sediment13 control BMPs (Strata, 2011a). The dried pits would ultimately be backfilled, graded, covered 

14 with topsoil, and reseeded to achieve the reclamation standards required by WDEQ/LQD 

15 (Strata, 2011a). The Applicant would attempt to complete reclamation of the mud pits within 

16 one construction season to minimize wind and water erosion. The reclaimed mud pits would be 

17 included in the radiation surveys that would be accomplished during the Proposed Action’s 

18 decommissioning so that no potential long-term impacts from radioactivity are present (Strata, 

19 2011a).

20

21 The Applicant estimates that 19 L/mo [5 gal/mo] of used oil would be generated and shipped to 

22 a local commercial recycler (Strata, 2012a). The Applicant also estimates that 9,842 L/d [2,600 

23 gal/d] of domestic sewage would be generated during construction; this waste would be 

24 managed in an onsite domestic waste-water system designed according to WDEQ/WQD 

25 standards (Strata, 2011a). 

26

27 The potential impacts of the management of liquid wastes during construction, therefore, would 

28 be SMALL.

29

30 Solid Waste

31

32 Solid wastes generated during the construction of the Proposed Action would be of limited 

33 quantity and volume. The estimated volume of each type of waste and the respective disposal 

34 practices that would be used by the Applicant to manage the wastes are described in SEIS 

35 Section 2.1.1 and are summarized as follows:

36

37 ■ Less than 9 kg/mo [20 lb/mo] of used oil filters and oily rags would be produced and shipped 

38 to a local commercial recycler.

■ 19 m3/wk [25 yd3 39 /wk] of solid waste not regulated by the NRC nor the EPA would be 

40 generated and disposed or recycled at an offsite local landfill.

■ Less than 1 m3/wk [1 yd3 41 /wk] of petroleum-contaminated soil would be transported by a 

42 waste-disposal contractor to a permitted facility in northeast Wyoming, such as the Campbell

43 County Landfill.

44 ■ Less than 100 kg/mo [220 lb/mo] of hazardous waste would be securely and appropriately 

45 accumulated at the Ross Project and transported by a hazardous-waste contractor to an 
DRAFT Environmental Impacts and Mitigation Measures

4-103

1 appropriately permitted, commercial treatment, storage and disposal (TSD) facility outside of 

2 Wyoming (Strata, 2012a).

3

4 The Applicant proposes to minimize the volume of used oil and hazardous waste by servicing its 

5 vehicles and equipment offsite and by limiting its chemical-reagent orders to quantities that can 

6 be consumed within the regents’ shelf lives (Strata, 2011a). 

7

8 Waste volumes are similar to those described in Section 4.4.12 of the GEIS. Thus, the potential 

9 impacts of the management of solid wastes during the construction of the Proposed Action 

10 would be SMALL.

11

12 4.14.1.2 Ross Project Operation

13

14 As described in GEIS Section 4.4.12, waste-management impacts during the operation of an 

15 ISR facility would be SMALL, based upon the required preoperational disposal agreement(s) for 

16 solid radioactive wastes in addition to regulatory controls such as the applicable permit and 

17 license conditions with which an Applicant must comply as well as the inspections the NRC and 

18 other regulatory agencies would perform (NRC, 2009). At the Ross Project, the UIC Permit for 

19 the Class I injection wells that has already been obtained by Strata for deep-well injection of 

20 liquid byproduct (i.e., radioactive) waste specifies operating conditions and reporting 

21 requirements with which the Applicant must comply (WDEQ/WQD, 2011). Design specifications 

22 related to radioactive waste that would need to be approved by the NRC include waste 

23 treatment and volume reduction techniques, surface-impoundment leak detection systems, and 

24 other routine monitoring activities that would further minimize the potential for impacts to the 

25 environment (NRC, 2009). 

26

27 Liquid Waste

28

29 As described in SEIS Section 2.1.1, liquid byproduct waste generated during ISR operations 

30 would include process bleed (an average of 1.5 percent of injection volume) and other process 

31 waste waters. The process bleed would be treated by a two-stage RO circuit during the 

32 Proposed Action, producing a minimized volume of brine and permeate. Permeate from the RO 

33 process would be re-used as plant make-up water or lixiviant. Excess permeate requiring 

34 disposal would be only generated during the first two and one-half years of ISR operations 

35 before aquifer restoration begins (Strata, 2011a). The Applicant proposes that excess 

36 permeate, up to 190 L/min [50 gal/min] would be discharged to the surface impoundments. The 

37 double-liner, leak-detection system the Applicant proposes for its surface impoundments, in 

38 addition to the monitoring and reserve-capacity requirements mandated by NRC regulations and 

39 NRC license conditions, would allow detection of any surface-impoundment spills or leaks 

40 before any significant release of material occurs (NRC, 2009). These requirements were also 

41 anticipated by the GEIS, when it concluded that similar waste-management techniques would 

42 result in SMALL impacts. Thus, the potential impacts of the Proposed Action’s use of surface 

43 impoundments for the management of liquid byproduct waste would be SMALL.

44

45 The Applicant estimates that approximately 240 L/min [62 gal/min] of brine and other process 

46 waters would be disposed of into the UIC-permitted Class I deep-injection wells that the 

47 Applicant has already obtained from the WDEQ/WQD (WDEQ/WQD, 2011). The lined surface 

48 impoundments and a storage tank with secondary containment would be used to manage the 
DRAFT Environmental Impacts and Mitigation Measures

4-104

1 brine before its disposal in the deep-injection wells (Strata, 2012b). The use of the surface 

2 impoundments for waste management and the disposal by deep-well injection that the Applicant

3 proposes are consistent with the waste-management practices described in the GEIS. 

4

5 The Applicant expects that ground water generated during the construction and development of 

6 recovery and injection wells would be disposed of in mud pits similarly to the disposal of drilling 

7 fluids generated during the construction phase. However, drilling fluids generated during 

8 development of wells completed in an aquifer affected by uranium-recovery operations would be 

9 disposed of in the lined retention ponds or via the deep disposal wells (Strata, 2012b).

10

11 The volume of used oil that would be produced during the Proposed Action’s operation and its 

12 management would be the same as during its construction (Strata, 2012a). The volume of 

13 domestic sewage, which would be managed in an onsite system, would be approximately 3,000 

14 L/d [800 gal/d] (Strata, 2012a).

15

16 The potential impacts of the management of liquid wastes during operation would therefore be 

17 SMALL.

18

19 Solid Waste

20

As described in SEIS Section 2.1.1, the Applicant estimates that approximately 80 m3 21 /yr [100 

yd3 22 /yr] of solid byproduct (i.e., radioactive) waste would be generated during the operation 

23 phase of the Proposed Action (Strata, 2012a). The Applicant proposes to minimize the quantity 

24 of byproduct solid waste by selecting high-efficiency filter media for uranium-recovery and 

25 aquifer-restoration circuits (Strata, 2011a). Getting more use out of filter media would minimize 

26 the quantity used as well as the waste generated during operation. This byproduct waste would 

27 be accumulated inside 208-L [55-gal], lined drums and stored in a restricted area of the CPP 

(Strata, 2011a). Full drums would later be sealed and then moved into a 15-m3 [20-yd3 28 ] roll-off 

29 container. Roll-off containers would be stored in a restricted area outside of the CPP where 

30 access is secured and restricted. Sealed roll-off containers would be transported to a 

31 radioactive-waste disposal facility licensed by the NRC or an Agreement State. This disposal 

32 would only be allowed by the NRC after preoperational agreements between the Applicant and 

33 the licensed facility(ies) have been executed. The Applicant has identified four facilities 

34 currently licensed to receive such byproduct waste and that can ensure adequate capacity for 

35 the solid byproduct waste generated by the Ross Project (Strata, 2012a).

36

37 Solid non-byproduct waste and hazardous-waste volumes generated during the Proposed 

38 Action’s operation would be similar to or less than that generated during its construction (Strata, 

39 2011a). Therefore, the potential impacts of the management of all solid wastes during Ross 

40 Project operation would be SMALL.

41

42 4.14.1.3 Ross Project Aquifer Restoration

43

44 In GEIS Section 4.4.12.3, the impacts associated with waste management during an ISR 

45 facility’s aquifer-restoration phase were evaluated. These were determined to be generally the 

46 same as those during its operation. Thus, the GEIS found that waste-management impacts 

47 would be SMALL. 
DRAFT Environmental Impacts and Mitigation Measures

4-105

1 Liquid Waste

2

3 Liquid byproduct (radioactive) wastes generated during the Proposed Action’s aquifer 

4 restoration would amount to approximately 740 L/min [190 gal/min] of brine. The Applicant

5 proposes to minimize the volume of liquid byproduct waste that would be generated while the 

6 Ross Project is in the aquifer-restoration phase by its limiting the ground-water sweep to the 

7 perimeter of a wellfield module, rather than throughout the entire module. As during operation, 

8 the two-stage RO circuit would reduce the volume of brine requiring disposal. Evaporation of 

9 stored brine from the surface impoundments would further reduce the volume of brine needing 

10 disposal by an estimated 36 L/min [9.3 gal/min]. All permeate from the RO process would be 

11 used for process water and aquifer restoration.

12

13 The volume of used oil that would be produced during the Proposed Action’s aquifer-restoration 

14 phase would be the same as that produced during its construction and operation (Strata, 

15 2012a). The volume of domestic sewage managed with the Ross Project’s onsite treatment 

16 system would decrease to approximately 1,100 L/d [300 gal/d] (Strata, 2012a) due to the 

17 smaller number of workers at the Ross Project during aquifer restoration. Thus, the potential 

18 impacts of the management of all types of liquid wastes during aquifer restoration at the 

19 Proposed Action would be SMALL.

20

21 Solid Waste

22

23 The management of solid wastes, including byproduct, radioactive and hazardous wastes, 

24 generated during the aquifer-restoration phase of the Proposed Action would be similar to its 

25 construction and operation phases (Strata, 2011a). The volume of office and municipal solid 

26 wastes would decrease due to the smaller workforce during aquifer restoration (i.e., 200 and 60 

27 vs. 20 workers), while the volume of byproduct and other radioactive wastes would also 

28 diminish, producing less and less waste contaminated by byproduct materials, as the aquifer is 

29 restored. Thus, the potential impacts of the management of solid wastes during aquifer 

30 restoration would be SMALL.

31

32 4.14.1.4 Ross Project Decommissioning

33

34 As described in GEIS Section 4.4.12, the impacts associated with liquid-waste management 

35 during decommissioning at an ISR facility would be SMALL and would be similar to the 

36 respective construction and operational impacts. However, the volume of solid byproduct waste 

37 and all other types of solid wastes generated during decommissioning would be substantially 

38 greater than during the other phases due to the decontamination, dismantling, demolishing, and 

39 disposal of the Ross Project components (Strata, 2012a). 

40

41 Liquid Waste

42

43 The Applicant estimates that less than 38 L/min [10 gal/min] of brine would be generated and 

44 disposed of by deep-well injection during the Proposed Action’s decommissioning (Strata, 

45 2012a). This volume would be a significant reduction from that generated during the other 

46 phases of the Proposed Action. The volume of used oil that would be generated during 

47 decommissioning and its management would be the same as that generated during operation 

48 (Strata, 2012a). The volume of domestic sewage that would be treated in the onsite system 
DRAFT Environmental Impacts and Mitigation Measures

4-106

1 would be approximately 4,500 L/d [1,200 gal/d] (Strata, 2012a). Thus, the potential impacts of 

2 the management of liquid wastes during the decommissioning phase of the Proposed Action 

3 would be SMALL.

4

5 Solid Waste

6

The Applicant estimates that decommissioning would generate 3,000 m3 [4,000 yd3 7 ] of solid 

8 byproduct waste (Strata, 2012a). The nature of this waste is described in SEIS Section 2.1.1. 

A typical ISR Project generates approximately 4,593 m3 [6,008 yd3 9 ] of byproduct waste, and 

10 Strata would generate less, thus the analysis in the GEIS is bounding (NRC, 2009). 

11

12 The onsite collection, minimization, and storage of this solid byproduct waste would follow the 

13 same techniques and SOPs as those described for the Proposed Action’s operation. The pre14 operational agreements with one or more appropriately licensed waste disposal facilities would 

15 govern the disposal of this waste the same as during the Ross Project’s operation. The 

16 Applicant proposes to reduce the quantity of solid byproduct waste by decontaminating as many 

17 surfaces as technically possible while using decontamination techniques such as high pressure 

18 washing, sand blasting, and acid rinsing that allow waste volumes to be reduced (Strata, 

19 2011a). Where possible, the Applicant intends to decontaminate equipment and building 

20 surfaces so that the mobile equipment, dismantled process equipment, and demolished building 

21 components could be reclassified for unrestricted use by demonstrating that radioactivity levels 

22 are below regulatory concern.

23

The Applicant estimates that decommissioning would generate 1,500 m3 [2,000 yd3 24 ] of solid 

25 non-byproduct waste. Such waste would consist of construction debris and decontaminated 

26 equipment and materials (Strata, 2012a). As described in Section 2.1.1 of this SEIS, the 

27 Applicant proposes this waste would be disposed of in local solid-waste landfills. The estimated 

28 volume of solid waste would be about twice the amount generated by the typical ISR facility

29 described in the GEIS (NRC, 2009), however the capacity of the local landfills are shown in the 

30 Applicant’s responses to the NRC’s Requests for Additional Information and the Applicant’s 

31 corresponding table indicates there would be sufficient local capacity for disposal of this volume 

32 (Strata, 2012a). 

33

34 The volumes of other typical solid and hazardous wastes including industrial or municipal waste, 

35 recyclable, demolition, and petroleum contaminated soil generated during the Proposed Action’s 

36 decommissioning would be similar to those generated during construction and operation (Strata, 

37 2012a). The potential impacts of the management of solid wastes during decommissioning, 

38 therefore, would be SMALL.

39

40 4.14.2 Alternative 2: No Action

41

42 Under the No-Action Alternative, the Ross Project would not be licensed and the land would 

43 continue to be available for other uses. However, the Applicant could continue preconstruction 

44 activities until that decision has been made. Thus, drilling fluids and muds from drillholes and 

45 wells installed to delineate the ore zone and to characterize the ground-water and the 

46 geotechnical, subsurface conditions at the Ross Project area would continue to generate wastes 

47 under the No-Action Alternative. These wastes would continue to be contained in mud pits 

48 constructed at the well sites (as described in SEIS Section 2.1.1) and then evaporated to 
DRAFT Environmental Impacts and Mitigation Measures

4-107

1 dryness. The dried pits would be backfilled, graded, covered with topsoil, and reseeded to 

2 achieve reclamation standards required by WDEQ/LQD (Strata, 2011a). No additional, distinct 

3 waste management impacts would result from the No-Action Alternative; thus, the potential 

4 impacts of waste management in the No-Action Alternative would be SMALL.

5

6 4.14.3 Alternative 3: North Ross Project

7

8 Under Alternative 3, the North Ross Project would generally be the same as the Proposed 

9 Action, except that the facility (i.e., the CPP, associated buildings, and auxiliary structures as 

10 well as the surface impoundments) would be located to the north of where it would be located in 

11 the Proposed Action, as described in SEIS Section 2.1.3. The wastes generated during this 

12 Alternative would be essentially the same as those generated during the Proposed Action 

13 during each of its phases: Alternative 3 would be constructed and operated the same as the 

14 Proposed Action, and its aquifer restoration and decommissioning would also be the same. 

15 Thus, the waste-management techniques and disposal strategies employed for the Proposed 

16 Action would be employed for Alternative 3. 

17

18 However, as described in SEIS Section 2.1.1, the lined surface impoundments would not 

19 require the construction of the CBW included in the design of the Proposed Action because of 

20 the south site’s higher water table. Consequently, the volume of liquid wastes generated at 

21 north site would be reduced by the volume of any leaks and/or ground water that would need to 

22 be dewatered from inside the CBW during facility operation, aquifer restoration, and 

23 decommissioning of Alternative 1. In addition, the volume of solid waste ultimately requiring 

24 disposal would be reduced by the small amount of material generated during the breach of the 

25 CBW during decommissioning. Therefore, potential impacts of waste management for 

26 Alternative 3 would be SMALL.

27

28 4.15 References

29

30 10 CFR Part 20. Title 10, “Energy,” Code of Federal Regulations, Part 20 “Standards for 

31 Protection Against Radiation.” Washington, DC: U.S. Government Printing Office. 

32

33 10 CFR Part 40. Title 10, “Energy,” Code of Federal Regulations, Part 40, “Domestic Licensing 

34 of Source Material.” Washington, DC: Government Printing Office. 1985, as amended.

35

36 10 CFR Part 40, Appendix A. Title 10, “Energy,” Code of Federal Regulations, Part 40, 

37 “Domestic Licensing of Source Material,” Appendix A, “Criteria Relating to the Operation of 

38 Uranium Mills and the Disposition of Tailings or Wastes Produced by the Extraction or 

39 Concentration of Source Material from Ores Processed Primarily for their Source Material 

40 Content.” Washington, DC: Government Printing Office. 1985, as amended. 

41

42 29 CFR Part 1910. Title 29, “Title,” Code of Federal Regulations, Part 1910, “Occupational 

43 Safety and Health Standards.” Washington, DC: Government Printing Office. 1974, as 

44 amended.

45

46 40 CFR Part 192. Title 40, “Protection of the Environment,” Code of Federal Regulations, Part 

47 192, “Health and Environmental Protection Standards for Uranium and Thorium Mill Tailings.” 

48 Washington, DC: Government Printing Office. 1983, as amended.
DRAFT Environmental Impacts and Mitigation Measures

4-108

1 40 CFR Subpart C. Title 40, “Protection of the Environment,” Code of Federal Regulations, 

2 Subchapter C. Washington, DC: Government Printing Office. 1971, as amended. 

3

4 49 CFR Part 171. Title 49, “Transportation,” Code of Federal Regulations, Part 171, “General 

5 Information, Regulations, and Definitions,” Subpart B, “Incident Reporting, Notification, BOE 

6 Approvals and Authorization.” Washington, DC: Government Printing Office. 2003, as 

7 amended.

8

9 49 CFR Part 172. Title 49, “Transportation,” Code of Federal Regulations, Part 185, 

10 “Hazardous Material Table, Special Provisions, Hazardous Materials Communication, 

11 Emergency Response Information, Training Requirements, and Security Plans.” Washington, 

12 DC: Government Printing Office. 1972, as amended.

13

14 APLIC (Avian Power Line Interaction Committee). Suggested Practices for Avian Protection on 

15 Power Lines: The State of the Art in 2006. CEC-50-2006-022. Washington, DC: Edison 

16 Electric Institute; Sacramento, CA: Avian Power Line Interaction Committee; Sacramento, CA: 

17 California Energy Commission. 2006.

18

19 BLM (U.S. Bureau of Land Management). Visual Resource Management. Manual 8400. 

20 Washington, DC: Government Printing Office. 2007. 

21

22 BLM. Visual Resource Inventory. Manual H–8410–1. Washington, DC: USBLM. 2010. 

23 Agencywide Documents Access and Management System (ADAMS) Accession No. 

24 ML13014A644. 

25

26 (US)CB (U.S. Census Bureau, U.S. Department of Commerce [DOC]). “State and County 

27 QuickFacts, Wyoming, Crook County, Campbell County.” At 

28 http://quickfacts.census.gov/qfd/states/56000.html (as of June 25, 2012). 2012a. 

29

30 (US)CB. “2006 – 2010 American Community Survey.” At http://factfinder2.census.gov (as of 

31 April 26 and May 2, 2012). 2012b. 

32

33 CEQ (Council of Environmental Quality). Environmental Justice, Guidance under the National 

34 Environmental Policy Act. Prepared for The Executive Office of the President. Washington, 

35 DC: Government Printing Office. December 1997. ADAMS Accession No. ML13022A298.

36

37 Countess, R., W. Barnard, C. Claiborn, D. Gillette, D. Latimer, T. Pace, and J. Watson. 

38 “Methodology for Estimating Fugitive Windblown and Mechanically Resuspended Road Dust 

Emissions Applicable for Regional Air Quality Modeling” in 10th 39 International Emission Inventory 

40 Conference Proceedings. Westlake Village, CA: Countess Environmental. May 2001. ADAMS 

41 Accession No. ML13022A448.

42

43 (US)DOT (U.S. Department of Transportation). Highway Traffic Noise Analysis and Abatement 

44 Policy and Guidance. Washington, DC: Noise and Air Quality Branch, Office of Environment 

45 and Planning, Federal Highway Administration, USDOT. June 1995. Accession No. 

46 ML13023A373.
DRAFT Environmental Impacts and Mitigation Measures

4-109

1 EOP (Executive Office of the President). Federal Actions to Address Environmental Justice in 

2 Minority Populations and Low-Income Populations. EO No. 12898. Washington, DC: 

3 Government Printing Office. February 1994. ADAMS Accession No. ML13023A255.

4

5 (US)EPA (U.S. Environmental Protection Agency). Protective Noise Levels. 

6 Condensed Version of EPA Levels Document. EPA 550/9-79-100. Washington, DC: USEPA. 

7 November 1978. ADAMS Accession No. ML13015A552. 

8

9 Ferguson, D. A Class III Cultural Resource Inventory of Strata Energy’s Proposed Ross ISR 

10 Uranium Project, Crook County, Wyoming (Redacted Version). Prepared for Strata Energy, 

11 Inc., Gillette, Wyoming. Butte, MT: GCM Services, Inc. 2010. 

12

13 Mackin, P.C., D. Daruwalla, J. Winterle, M. Smith, and D.A. Pickett. NUREG/CR–6733, “A 

14 Baseline Risk-Informed Performance-Based Approach for In Situ Leach Uranium Extraction 

15 Licensees.” Washington, DC: NRC. September 2001.

16

17 (US)NPS (U.S. National Park Service, US Department of Interior). Jeffery R. Hanson and Sally 

18 Chirino. Ethnographic Overview and Assessment of Devils Tower National Monument, 

19 Wyoming. Paper 4. Washington, DC: USNPS. 1997. 

20

21 (US)NRC (U.S. Nuclear Regulatory Commission). NUREG–0706. “Final Generic 

22 Environmental Impact Statement on Uranium Milling Project M-25.” Washington, DC: NRC. 

23 September 1980. ADAMS Accession Nos. ML032751663, ML0732751667, and ML032751669. 

24

25 (US)NRC. NUREG–1508. “Final Environmental Impact Statement To Construct and Operate

26 the Crownpoint Uranium Solution Mining Project, Crownpoint, New Mexico.” Washington, DC: 

27 NRC. February 1997. ADAMS Accession No. ML082170248. 

28

29 (US)NRC. “Environmental Assessment for Renewal of Source Material License No. SUA-1534, 

30 Crow Butte Resources Incorporated, Crow Butte Uranium Project, Dawes County, Nebraska.” 

31 Washington, DC: NRC. 1998. Accession No. ML071520242. 

32

33 (US)NRC. NUREG–1748. “Environmental Review Guidance for Licensing Actions Associated 

34 with NMSS Programs.” Washington, DC: NRC. August 2003. ADAMS Accession No. 

35 ML032450279. 

36

37 (US)NRC. “Policy Statement on the Treatment of Environmental Justice Matters in NRC 

38 Regulatory and Licensing Actions.” No. 7590-01-P. Washington, DC: NRC. 2004. ADAMS 

39 Accession No. ML033380930. 

40

41 (US)NRC. NUREG–1910. “Generic Environmental Impact Statement for In-Situ Leach 

42 Uranium Milling Facilities.” Volumes 1 and 2. Washington, DC: NRC. 2009. ADAMS 

43 Accession Nos. ML082030185 and ML091480188. 

44

45 (US)NRC. NUREG–1910, Supplement 1. “Environmental Impact Statement for the Moore 

46 Ranch ISR Project in Campbell County, Wyoming, Supplement to Generic Environmental 

47 Impact Statement for In-Situ Leach Uranium Milling Facilities, Final Report.” Washington, DC: 

48 USNRC. August 2010. ADAMS Accession No. ML102290470. 
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4-110

1 (US)NRC. NUREG–1910, Supplement 2. “Environmental Impact Statement for the Nichols 

2 Ranch ISR Project in Campbell and Johnson Counties, Wyoming. Supplement to the Generic 

3 Environmental Impact Statement for In-Situ Uranium Leach Milling Facilities.” Washington, DC: 

4 USNRC. January 2011a. ADAMS Accession No. ML103440120. 

5

6 (US)NRC. NUREG–1910, Supplement 3. “Environmental Impact Statement for the Lost Creek 

7 ISR Project in Sweetwater County, Wyoming. Supplement to the Generic Environmental Impact 

8 Statement for In-Situ Uranium Leach Milling Facilities.” Washington, DC: USNRC. June 

9 2011b. ADAMS Accession No. ML11125A006. 

10

11 (US)OSHA (U.S. Occupational Safety and Health Administration). “Wyoming Plan.” 2011. At 

12 http://www.osha.gov/dcsp/osp/stateprogs/wyoming.html (as of April 24, 2012). 

13

14 Stout, Dennis E. and R. Mark Stover. “The Smith Ranch Uranium Project” from The Uranium 

15 Institute Twenty-Second Annual Symposium, September 3–5, 1997, London, United Kingdom.” 

16 London: The Uranium Institute. December 1997.

17

18 Strata (Strata Energy, Inc.). Ross ISR Project USNRC License Application, Crook County, 

19 Wyoming, Environmental Report, Volumes 1, 2 and 3 with Appendices. Docket No. 40-09091. 

20 Gillette, WY: Strata. 2011a. ADAMS Accession Nos. ML110130342, ML110130344, and 

21 ML110130348.

22

23 Strata. Ross ISR Project USNRC License Application, Crook County, Wyoming, Technical 

24 Report, Volumes 1 through 6 with Appendices. Docket No. 40-09091. Gillette, WY: Strata. 

25 2011b. ADAMS Accession Nos. ML110130333, ML110130335, ML110130314, ML110130316, 

26 ML110130320, and ML110130327.

27

28 Strata. Air Quality Permit Application for Ross In-Situ Uranium Recovery Project. Prepared for 

29 Strata Energy, Inc. Sheridan, WY: Inter-Mountain Laboratories, IML Air Science. 2011c. 

30 ADAMS Accession No. ML11222A060.

31

32 Strata and Crook County. Memorandum of Understanding for Improvement and Maintenance of 

33 Crook County Roads Providing Access to the Ross ISR Project. Sundance, WY: Crook 

34 County. April 6, 2011d. ADAMS Accession No. ML111170303.

35

36 Strata. Ross ISR Project USNRC License Application, Crook County, Wyoming, RAI Question 

37 and Answer Responses, Environmental Report, Volume 1 with Appendices. Docket No. 40-

38 09091. Gillette, WY: Strata. 2012a. ADAMS Accession No. ML121030465. 

39

40 Strata. Ross ISR Project USNRC License Application, Crook County, Wyoming, RAI Question 

41 and Answer Responses, Technical Report, Volumes 1 and 2 with Appendices. Docket No. 40-

42 09091. Gillette, WY: Strata. 2012b. ADAMS Accession Nos. ML121020357 and 

43 ML121020361. 

44

45 WDEQ/AQD (Wyoming Department of Environmental Quality/Air Quality Division). “Air Quality.” 

46 Rules and Regulations, Chapter 3. Cheyenne, WY: WDEQ/AQD. 2010. 
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4-111

1 WDEQ/AQD. Permit to Construct, Air Quality Permit #12198. Cheyenne, WY: WDEQ/AQD. 

2 2011. September 13, 2011. ADAMS Accession No. ML112770430.

3

4 WDEQ/LQD (Wyoming Department of Environmental Quality/Land Quality Division). “Noncoal 

5 In Situ Mining,” Rules and Regulations, Chapter 11. Cheyenne, WY: WDEQ/LQD. 2005.

6

7 WDEQ/LQD. Cumulative Hydrologic Impact Assessment of Coal Mining in the Middle Powder 

8 River Basin, Wyoming. WDEQ-CHIA-27. Cheyenne, WY: WDEQ/LQD. March 2011. 

9

10 WDEQ/WQD. “Implementation Policy for Radium Effluent Limits in WYPDES Permits.” At 

11 http://deq.state.wy.us/wqd/wypdes_permitting/index.asp (as of June 25, 2012). 2005. 

12 ADAMS Accession Nos. ML13015A683. 

13

14 WDEQ/WQD (Wyoming Department of Environmental Quality/Water Quality Division). “Water 

15 Quality,” Rules and Regulations, Chapter 1. Cheyenne, WY: WDEQ/WQD. 2007. 

16

17 WDEQ/WQD. Strata Energy, Inc. – Ross Disposal Injection Wellfield, Final Permit 10-263, 

18 Class I Non-hazardous, Crook County, Wyoming. Cheyenne, WY: WDEQ/WQD. April 2011. 

19

20 WDWS (Wyoming Department of Workforce Services). “Labor and Employment,” Rules and 

21 Regulations, Chapter 11. Cheyenne, WY: WDWS. 2012. 

DRAFT Cumulative Impacts

5-1

1 5 CUMULATIVE IMPACTS

2

3 5.1 Introduction

4

5 The Council on Environmental Quality’s (CEQ’s) National Environmental Policy Act (NEPA) 

6 regulations, as amended (Title 40 Code of Federal Regulations [CFR] Parts 1500 – 1508) (40 

7 CFR Parts 1500 – 1508), define cumulative effects as “the impact on the environment that 

8 results from the incremental impact of the action when added to other past, present, and 

9 reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or 

10 person undertakes such other actions” (40 CFR Parts 1500 – 1508). Cumulative impacts can 

11 result from individually minor, but collectively significant, actions that take place over a period of 

12 time. (For the purposes of this analysis, the phrase “cumulative impacts” is synonymous with 

13 the phrase “cumulative effects.”) A proposed project could contribute to incremental cumulative 

14 impacts when its environmental impacts overlap with those of other past, present, or reasonably 

15 foreseeable future actions in a given area. For this Supplemental Environmental Impact 

16 Statement (SEIS), other past, present, and future actions near the Ross Project include (but are 

17 not limited to) cattle and sheep grazing, agricultural production, other uranium-recovery 

18 production, coal mining, oil and gas production, and wind-farm operation.

19

20 This analysis of the cumulative impacts of the Proposed Action is based upon publicly available 

21 information on existing and proposed projects, information in the Generic Environmental Impact 

22 Statement (GEIS) (NRC, 2009), and general knowledge of the conditions in Wyoming and in the 

23 nearby communities. The primary activities currently taking place in the area of the Ross 

24 Project are mineral mining and uranium recovery as well as oil and gas development. The 

25 Power River Basin contains the largest deposits of coal in the United States as well as 

26 significant reserves of other natural resources including uranium, oil, and gas (NRC, 2010). 

27 There has been a resurgence in interest in these mining and recovery activities. 

28

29 This section evaluates the potential for cumulative impacts associated with the Ross Project and 

30 other past, present, and reasonably foreseeable future actions as described below in Section

31 5.2. The GEIS provides an example methodology for conducting a cumulative-impacts 

32 assessment (NRC, 2009). This methodology, which has been used by U.S. Nuclear Regulatory 

33 Commission (NRC) staff in its cumulative-impact analysis in this SEIS, is discussed in Section 

34 5.3. 

35

36 5.2 Other Past, Present, and Reasonably Foreseeable Future Actions 

37

38 The Ross Project area, where the Proposed Action would be sited, is located just within the 

39 Nebraska-South Dakota-Wyoming Uranium Milling Region (NSDWUMR) as defined in the GEIS 

40 (NRC, 2009). The Ross Project encompasses approximately 697 ha [1,721 ac] of land, all of 

41 which is located in Crook County. It is located within the Lance District (see Figure 2.1 in 

42 Section 2), so-called due to its location above the uranium-rich Late Cretaceous Lance 

43 Formation as discussed earlier in Section 3.4. The surface owners of the Ross Project area 

44 include private parties (553 ha [1,367 ac]), the State of Wyoming (127 ha [314 ac]), and the U.S. 

45 Bureau of Land Management (BLM) (16ha [40 ac]). The subsurface-mineral owners include the 

46 same parties, except that of 553 ha [1,367 ac] of privately owned land, 65 ha [161 ac] of 

47 subsurface mineral rights are administered by BLM. Somewhat unusually, the surface water at 

48 the Ross Project predominantly flows in a northeasterly direction to the Little Missouri River, 
DRAFT Cumulative Impacts

5-2

1 while the ground water, which is part of the Powder River Basin regime, flows mostly westerly. 

2 This bifurcation is important to note as cumulative impacts are identified and evaluated. The 

Ross Project area, at approximately 7 km2 [somewhat less than 3 mi2 3 ] in size, represents 

approximately 0.03 percent of the 25,900 km2 [10,000 mi2 4 ] of the entire Powder River Basin.

5

6 5.2.1 Actions

7

8 The historical and current actions (land uses) on and near the Ross Project area include 

9 livestock grazing, crop cultivation and agriculture, wildlife habitats, oil recovery, and, to the 

10 northeast, bentonite mining (Strata, 2011a). The historical Nubeth Joint Venture (Nubeth) also 

11 was operated on the lands, which comprise the proposed Ross Project. SEIS Section 3.2 

12 discusses these historical and present land uses in more detail; these land uses are expected to 

13 continue into the future, albeit to a lesser extent, while the Ross Project is operating in the area. 

14 It should be noted that no long-term, permanent changes to the environment are anticipated as 

15 a result of the Ross Project within about 8 km [5 mi] of the Ross Project area, except for the 

16 potential installation of additional roads. The extensive aquifer restoration and site reclamation 

17 activities the Applicant would perform during the Ross Project’s decommissioning would ensure 

18 that no permanent land-use changes occur on the Ross Project area itself.

19

20 Several industries presently conduct activities in and near Crook County, activities which could 

21 have environmental impacts that, when combined with those of the Ross Project, could be 

22 greater than the individual impacts of the Ross Project. In addition, some of these activities, 

23 such as uranium recovery as well as oil and gas recovery, could be actively expanded within

24 Crook County and into its neighboring counties. These activities are described below.

25

26 5.2.1.1 Uranium Recovery

27

28 Uranium was first mined in Wyoming in 1920. Uranium discovered in the Powder River and 

29 Wind River Basins during the 1950s, and continued exploration for uranium resulted in 

30 discovery of additional sedimentary uranium deposits in the major basins of central and 

31 southern Wyoming, including the Powder River Basin. Continued uranium exploration resulted 

32 in discovery of additional sedimentary uranium deposits in the major basins of central and 

33 southern Wyoming. Uranium production in Wyoming declined in the mid-1960s, but increased 

34 again in the late 1960s and 1970s. Conventional mine production peaked in 1980 and then 

35 decreased in the early 1980s through the early 1990s when in situ recovery (ISR) facilities were 

36 developed. The total uranium mine production in the United States in 2007 was 2.1 million kg 

37 [4.5 million lb], almost half of which occurred in the southernmost Powder River Basin. ISR 

38 replaced conventional mining and milling as the preferred means for extracting uranium in the 

39 U.S. Currently, only ISR facilities are extracting uranium in Wyoming. 

40

41 Interest in uranium-recovery has translated into several ISR projects in Wyoming. The Ross 

42 Project is one. In addition, the Applicant indicates that it could develop at least four additional 

43 satellite uranium-recovery areas within the larger Lance District over the next few years. 

44 Several other ISR projects are currently licensed in Wyoming as well, with two facilities 

45 operating and two ready for construction in the Powder River Basin (see Figure 5.1).

46 None of these operating and/or licensed ISR projects are located in Crook County (the location 

47 of the proposed Ross Project) nor have any other Crook County ISR facilities be officially 

48 proposed to the U.S. Nuclear Regulatory Commission (NRC). However, four ISR projects are 
DRAFT Cumulative Impacts

5-3

1 reportedly in the very early stages of development in Crook County (Strata, 2012a). In addition, 

2 two licensed ISR facilities are located in adjacent Campbell County (satellite areas of the Smith 

3 Ranch ISR Project, which is currently operating, and the Moore Ranch, which is still to be 

4 constructed). Two other ISR facilities overlap both Campbell and Johnson Counties (Willow 

5 Creek, which is currently operating, and Nichols Ranch, which is licensed and under 

6 construction). 

7

8 The Applicant describes in its license application the types and sequence of its planned 

9 development of the Lance District. The Applicant has identified significant uranium resources 

10 within the District, and it intends for the Ross Project to be the first of several ISR areas. These 

11 potential satellite areas could consist of those shown in Figure 2.2 in SEIS Section 2.1.1, 

12 including, to the north, Ross Amendment Area 1 and, to the south end of the Lance District, the 

13 Kendrick, Richards, and Barber satellite areas (Strata, 2012a). If additional wellfields were to be 

14 developed by the Applicant and licensed by the NRC, the Ross Project’s Central Processing 

15 Plant (CPP) would be used to process pregnant solutions from these satellite areas into 

16 yellowcake. In addition, the Applicant also proposes that ion-exchange (IX) resins loaded with 

17 uranium would be accepted at the Ross Project’s CPP from other offsite ISR facilities (referred 

18 to as “toll milling”) or companies and/or from water-treatment plants (Strata, 2011a). This

19 additional potential use of the CPP at the Ross Project is the reason that the Plant is designed 

20 for four times the capacity needed for only the Ross Project.

21

22 Lance District

23

24 The four satellite areas within the Lance District that the NRC staff identifies as reasonably 

25 foreseeable are as follows:

26

27 Ross Amendment Area 1

28

29 This area would be an extension of the proposed Ross Project to the north and west. This area 

30 would not increase the overall production rate of yellowcake, but rather it would increase the 

31 operating life of the Ross Project. As uranium production from early wellfields within the Ross 

32 Project area begins to diminish and the wellfields begin to enter the aquifer-restoration phase of 

33 the proposed Project, additional wellfields in the Ross Amendment Area 1 could be brought into 

34 production by the Applicant. The Ross Amendment Area 1 could extend the lifetime of the Ross 

35 Project by several years as shown in Figure 5.4 (Strata, 2012a). 

36

37 Kendrick Satellite Area

38

39 The Kendrick satellite area would be contiguous to the Ross Project area as shown in Figure 

40 2.2 in SEIS Section 2.1.1. However, unlike the Ross Amendment Area 1, the Kendrick satellite 

41 area would allow the Applicant to increase its production of yellowcake to approximately 

42 680,000 kg/yr [1.5 million lb/yr] (Strata, 2012a).
5-4

Figure 5.1

Eighty-Kilometer- (Fifty-Mile-)

Radius Area around Ross Project Area

Source: Strata, 2012a.
DRAFT Cumulative Impacts

5-5

1 Richards Satellite Area

2

3 The Richards satellite area would be contiguous to the Kendrick satellite area. The uranium4 rich solutions extracted from this satellite area would be piped to the Ross Project’s CPP for 

5 uranium recovery or, potentially, piped to the Barber satellite area as described below (Strata, 

6 2012a).

7

8 Barber Satellite Area

9

10 Although the Applicant’s plans for development of the Lance District are not yet complete, Strata 

11 anticipates that a remote IX-only plant could be constructed at the Barber satellite area. This 

12 would mean that the pregnant, uranium-rich solutions brought to the surface at the Barber 

13 satellite area would be treated by IX to yield uranium-loaded resins, which would then be 

14 trucked to the Ross Project’s CPP for further processing (e.g., resin elution) (Strata, 2012a). 

15 This additional uranium would increase the CPP’s output to approximately 993,000 kg/yr [2.19 

16 million lb/yr]. In addition, the Applicant would investigate the possibility of transferring pregnant 

17 solutions from wellfields in the Richards satellite area to the remote IX facility at the Barber 

18 satellite area before transfer to the CPP at the Ross Project area.

19

20 Other Potential ISR Facilities within 80 Kilometers [50 Miles] of the Ross Project

21

22 There are no uranium recovery or nuclear-fuel-cycle projects currently located within 80 km [50 

23 mi] of the Ross Project area nor have any Letters of Intent or license applications been filed with 

24 the NRC for any ISR projects within 80 km [50 mi] (Strata, 2011a; NRC, 2013). An 80-km [50-

25 mi]-radius area from the Ross Project is shown in Figure 5.1. There are, however, four other 

26 uranium-recovery operations in various very early planning stages located within 80 km [50 mi] 

27 of the Ross Project, including the following:

28

29 Potential Aladdin Project

30

31 This potential ISR Project would be located in Crook County, approximately 66 km [41 mi] east32 northeast of the Ross Project, although the driving distance to this project would be 

33 approximately 113 km [70 mi]. The Aladdin Project is being considered by Powertech Inc. and 

34 comprises approximately 7,099.8 ha [17,554 ac]. 

35

36 Potential Elkhorn Project

37

38 This potential ISR Project is currently being evaluated by NCA Nuclear, Inc. (a wholly owned 

39 subsidiary of Bayswater Uranium Corporation). This Project would also be located in Crook 

40 County, approximately 26 km [16 mi] from the Ross Project (driving distance would be 

41 approximately 32 km [20 mi]). It is currently estimated that this Project’s area of 2,110 ha [5,215 

42 ac] may ultimately yield approximately 544,000 kg [1.2 million lb] of uranium. The Project is 

43 located near the former, and decommissioned, Homestake Hauber Uranium Mine (see below).

44

45 Potential Hauber Project

46

47 The potential Hauber ISR Project would also be owned by NCA Nuclear, Inc., in a joint venture 

48 with Ur-Energy Inc. This Project would be located approximately 23km [14 mi] from the Ross 
DRAFT Cumulative Impacts

5-6

1 Project area, or 32 km [20 mi] if driven, and would comprise approximately 469 ha [1,160 ac]. 

2 The total uranium production from this Project is estimated at 680,000 kg [1.5 million lb] (Strata, 

3 2012a). This Project would be located near the now-closed Hauber Uranium Mine, which was 

4 operated between 1958 and 1966 (Strata, 2011a), which is discussed below.

5

6 Potential Alzada Project

7

8 This Project would be owned and operated by NCA Nuclear, Inc. and would comprise 

9 approximately 10,000 ha [25,000 ac]. It would be located approximately 62 km [39 mi] north10 northeast of the Ross Project area (driving distance would be approximately 129 km [80 mi]) 

11 (Strata, 2012a).

12

13 Other ISR Facilities within the Powder River Basin

14

15 There are four ISR projects in various stages of NRC’s licensing process and/or currently 

16 operating or being constructed within the Powder River Basin, all of which are located in 

17 Wyoming. The 80-km [50-mi] cumulative-impacts area does not include the entire Powder River 

18 Basin. Two of these facilities are currently operating; two have been licensed, one of which has 

19 begun construction. The owner of a fifth ISR project has conveyed a Letter of Intent to submit a 

20 license application to the NRC, but the application has not yet been submitted. These ISR 

21 projects include the following:

22

23 Smith Ranch ISR Project

24

25 This is a uranium-recovery project currently being operated by Power Resources Inc. (dba 

26 Cameco Resources Inc. [Cameco]). The Smith Ranch ISR Project is primarily located in 

27 Converse County, Wyoming, but the operation includes several remote satellite areas in other 

28 Wyoming counties that are not located in the Powder River Basin. A license application to 

29 renew and to expand Source Materials License SUA-1548 for the Smith Ranch Project was 

30 received by the NRC in February 2012 (see Docket No.40-8964). If the NRC grants a license 

31 as proposed, the renewed license would allow Cameco to continue conducting ISR activities at 

32 its Smith Ranch Project as well as to initiate and/or expand ISR activities at its associated and 

33 remote ISR satellite areas: 1) the Highlands Uranium Project and the Reynolds Ranch ISR 

34 satellite areas, both also located in Converse County; 2) the Gas Hills ISR satellite area in 

35 Fremont and Natrona Counties, Wyoming; 3) the North Butte ISR satellite area in Campbell 

36 County, Wyoming; and 4) the Ruth ISR satellite area in Johnson County, Wyoming (NRC, 

37 2013). 

38

39 Willow Creek ISR Project

40

41 The Willow Creek ISR Project is located in Johnson County in Wyoming. This Project is owned 

42 by Uranium One (see Docket No. 40-8502). Currently, its NRC license is in timely renewal as of 

43 May 2008 (i.e., a renewal license application has been submitted and the NRC is currently 

44 engaged in technical review of that application). 
DRAFT Cumulative Impacts

5-7

1 A license application for the Ludeman ISR Project was originally submitted to the NRC in 

2 January 2010, but it was subsequently withdrawn in May 2010. A license application was

3 resubmitted by the owner of the Project, Uranium One, in December 2011, where three specific 

4 subdivisions of the Ludeman area, which is located in Converse County, would be satellites of 

5 the Willow Creek ISR Project, which is located in Johnson County (NRC, 2013). Both of these 

6 Projects are situated in the Powder River Basin. The Ludeman ISR Project consists of 

7 approximately 8,000 ha [20,000 ac]; the Willow Creek ISR Project is approximately 5,500 ha 

8 [13,600 ac].

9

10 Nichols Ranch ISR Project

11

12 The Nichols Ranch ISR Project is located in Johnson and Campbell Counties of Wyoming. It is 

13 owned by the Uranerz Corporation (Uranerz) and is comprised of 1,251 ha [3,091 ac]. Its NRC 

14 license has been granted, and the facility is currently under construction (see Docket No. 40-

15 9067) (NRC, 2013). Uranerz currently has an Underground Injection Control (UIC) Permit 

16 Application pending at Wyoming Department of Environmental Quality (WDEQ). Uranerz has 

17 signed a toll-milling agreement with the owner of the Smith Ranch ISR Project, Cameco, to 

18 transfer uranium-loaded IX resins from the Nichols Ranch ISR Project to the Smith Ranch 

19 Project for final processing to yellowcake.

20

21 Moore Ranch ISR Project

22

23 The Moore Ranch ISR Project is located in Campbell County, Wyoming; it is owned by Energy 

24 Metals Corporation, a wholly owned subsidiary of Uranium One. It is comprised of 

25 approximately 2,879 ha [7,110 ac]. It is currently licensed by the NRC to operate through 

26 September 2020 (see Docket No. 40-9073) (NRC, 2013); construction on this ISR facility has 

27 not yet begun. 

28

29 Reno Creek ISR Project

30

31 AUC LLC, submitted a Letter of Intent to the NRC on November 3, 2010, indicating AUC LLC’s 

32 intention to site, design, license, construct, and operate an ISR facility in Campbell County, 

33 Wyoming. According to publically available information, the NRC currently anticipates receiving 

34 AUC LLC’s license application in April 2012 (NRC, 2012c).

35

36 Table 5.1 presents these Projects and indicates the respective linear distances from the Ross 

37 Project; Figure 5.1 shows these Projects’ locations.
DRAFT Cumulative Impacts

5-8

1

Table 5.1

Uranium-Recovery Projects within 80 Kilometers [50 Miles] of

Ross Project Area

Project Owner County

Direction

and

Distancea

(km [mi]) Status

Smith Ranch

License SUA-1548

North Butte

Ruby Ranch

Cameco 

Resources Inc./

Power 

Resources Inc.

Converse

Campbell

Campbell

SSW

180 km

[110 mi]

Operating.

Renewal and 

expansion (additional 

satellite areas) license 

application in 

technical review. 

Construction activities 

are occurring at the 

North Butte site.

Ruby Ranch 

expansion license 

application not yet 

submitted.

Willow Creek

(Formerly Irigaray/

Christianson 

Ranch)

License SUA-1341

Ludeman 

Allemand-Ross

Uranium One Johnson 

and 

Campbell

Converse

Converse

WSW

120 km

[75 mi]

Operating.

Renewal license 

application in technical 

review. Expansion to 

include Ludeman 

(license application 

has been submitted) 

and, later, AllemandRoss (license 

application has not 

been submitted) 

satellite areas.

Nichols Ranch

License SUA-1597

Uranerz Energy 

Corporation

Johnson 

and 

Campbell

SW

120 km

[75 mi]

Licensed and

under construction.

Moore Ranch

License SUA-1596

Energy Metals 

Corporation/

Uranium One

Campbell SW

150 km

[90 mi]

Licensed, but not yet 

under construction.

Reno Creek AUC LLC Campbell Letter of Intent filed, 

license application is 

not yet submitted.

2 Source: Strata, 2012a.

3 Note:

a 4 Approximate distance from the Ross Project area to the respective ISR project in “as the crow flies” 

5 (i.e., straight line) in kilometers [miles].

6

7

8
DRAFT Cumulative Impacts

5-9

1 Past ISR Facilities within 80 Kilometers [50 Miles] of the Ross Project

2

3 In addition to the present and reasonably foreseeable uranium-recovery facilities described 

4 above, it should be noted that, historically, two uranium-recovery facilities were located in the 

5 80-km [50-mi] area surrounding the Ross Project area. The first was a historic uranium mine 

6 near Hulett, and the second, Nubeth, was identified above and has been included in this SEIS’s 

7 analysis of pre-licensing baseline data as well as cumulative impacts in this section. 

8

9 The historic Homestake Hauber Uranium Mine was operated by the Homestake Mining 

10 Company between 1958 – 1966; the mine closed in 1966. It is also located in Crook County, 

11 approximately 19 km [12 mi] to the northeast of the Ross Project. This mine is no longer a 

12 contributor to cumulative impacts in the area because it is not operating and, thus, no longer 

13 producing impacts related to traffic, water resources, air quality, noise, and so forth. However, it 

14 is now a part of the area currently being explored for additional potential uranium recovery by 

15 NCA Nuclear, Inc., in a joint venture with Ur-Energy Inc. The potential Hauber ISR Project is 

16 described above; the Project is currently in the planning stages. This Project would be the 

17 nearest ISR uranium-recovery project to the proposed Ross Project 

18

19 Nubeth was described in SEIS Sections 2.1.1 and 3.5.3. This research and development ISR 

20 uranium-recovery operation operated between 1978 – 1986. Nubeth was decommissioned 

21 according to NRC and WDEQ requirements, and final approval for its decommissioning was 

22 issued between 1983 – 1986. Additional information regarding potential impacts from this 

23 historical operation is included in this SEIS Section assessing cumulative impacts.

24

25 5.2.1.2 Mining

26

27 Both coal as well as other natural resources are mined in and around Crook, Weston, and 

28 Campbell counties. Indeed, Powder River Basin coal mines supplies over 96 percent of the 

29 coal produced in Wyoming each year (BLM 2005a; BLM 2005b; BLM2005c), and Wyoming 

30 produces the greatest amount of coal in the U.S. Thus, substantial mining activities occur 

31 throughout the Basin, and coal mining continues to be the most prolific mining activity in the 

32 region.

33

34 Coal Mining

35

36 Coal mining in the Powder River Basin began during 1883, and underground coal mines began 

37 operation during 1894. The Powder River Basin emerged as a major coal-production area 

38 during the 1970s and early 1980s. The largest area, the Gillette coalfield, is approximately 24 

39 km [15 mi] wide and extends from approximately 35 km [22 mi] north of Gillette, Wyoming, to 

40 approximately 40 km [25 mi] south of Wright, Wyoming. A second coal area is approximately 32 

41 km [20 mi] wide, extending from Sheridan, Wyoming, north to the Wyoming-Montana state line. 

42 In 2007, this region accounted for approximately 97 percent of Wyoming's production and 

43 hosted the 10 largest coal mines in the U.S. Coal production in the Wyoming portion of the 

44 Basin is expected to grow at an annual rate of 2 – 3 percent per year. Additional coal leases 

45 and associated lands may be required to keep up with the world’s demand (BLM, 2009e).

46

47 The Powder River Federal Coal Region was decertified as a federal coal production region by 

48 the Powder River Regional Coal Team in 1990, which allowed leasing to occur in the region on 
DRAFT Cumulative Impacts

5-10

1 an application basis. Because of decertification, United States coal production increased 11 

2 percent, from 900,000 t [1 million T] in 1990 to 1.1 million [1.2 million T] in 2007 (BLM 2009a). 

3 From 1990 to 2008, the BLM Wyoming State Office held 25 competitive lease sales and issued 

4 19 new federal coal leases containing more than 5.7 billion tons of coal using the “lease by 

5 application” process (BLM 2005a; BLM 2005b; BLM 2005c). In 2003, the cumulative disturbed 

6 land area attributable to coal mines within the Powder River Basin totaled nearly 28,000 ha 

7 [70,000 ac]. Reasonably foreseeable future development projects contributing to the estimate 

8 of the cumulative acreage disturbed range from 47,400 – 50,600 ha [117,000 – 125,000 ac] in 

9 2015. Other development related to coal includes railroads, coal-fired power plants, major (230 

10 kV) transmission lines, and coal technology projects. The total land area of other coal-related 

11 disturbance in the Powder River Basin in 2003 was nearly 2,000 ha [5,000 ac]. 

12

13 Within 80 km [50 mi] of the Ross Project there are nine active coal mines (Strata, 2012a). 

14 Table 5.2 lists surface coal mines within 80 km [50 mi]; the respective locations are shown in 

15 Figure 5.1. 

16

Table 5.2

Active Coal Mines within 80 Kilometers [50 Miles] of

Ross Project Area

Mine Name Owner

Straight-Line 

Distance

km [mi]

Driving 

Distance

km [mi]

Belle Ayr Mine Alpha Coal West, Inc. 64 [40] 103 [64]

Buckskin Mine Buckskin Mining Company 47 [29] 108 [67]

Caballo Mine Peabody Caballo 

Coal L.L.C.

63 [39] 109 [68]

Coal Creek Mine Thunder Basin Coal Co. 

L.L.C.

72 [45] 137 [85]

Cordero Rojo Mine Cloud Peak Energy/

Cordero Rojo Mine

68 [42] 119 [74]

Dry Fork Mine Western Fuels Wyoming Inc. 45 [28] 85 [53]

Eagle Butte Mine Alpha Coal West Inc. 48 [30] 93 [58]

Rawhide Mine Peabody Energy 

Rawhide Mine

47 [29] 100 [62]

Wyodak Mine Wyodak Resources 

Development

45 [28] 71 [44]

17 Source: Wyoming State Mine Inspector, 2010; BLM, 2012, as included in Strata, 21012a.

18

19 Bentonite Mining

20

21 Bentonite is weathered volcanic ash that is used in a variety of products, including drilling muds 

22 and cat litters, because of its absorbent properties. There are 10 bentonite-producing mines in 

23 in the 80-km [50-mi] area surrounding the proposed Ross Project area. One, the Oshoto Mine, 

24 is 8 km [5 mi] (driving distance) from the Ross Project area. The next two closest bentonite 

25 mines are approximately 56 – 69 km [35 – 43 mi] from the Ross Project area.
DRAFT Cumulative Impacts

5-11

1 Other Mining

2

3 Sand, gravel, and clinker (or “scoria”) have been and continue to be mined in the Powder River 

4 Basin. Aggregate, which is sand, gravel, and stone, is used for construction purposes. The 

5 largest aggregate operation is located in the Powder River Basin in northern Converse County, 

6 and it has an associated total disturbance area of approximately 27 ha [67 ac], of which 1.62 ha 

7 [4 ac] have been reclaimed. Scoria is used as aggregate where alluvial terrace gravel or in8 palace granite/igneous rock is not available. Scoria generally is mined in Converse and 

9 Campbell Counties, in the western portion of the Powder River Basin (BLM, 2005a; BLM, 

10 2005b; BLM, 2005c). None of these are within 80 km [50 mi] of the Ross Project area.

11

Table 5.3

Active Bentonite Mines within 80 Kilometers [50 Miles] 

of Ross Project Area

Mine Name Owner

Straight-Line 

Distance

km [mi]

Driving 

Distance

km [mi]

ACC South Dakota American Colloid 

Company

74 – 80

[46 – 55]

129

[80]

Alzada North American Colloid 

Company

56 – 65

[35 – 40]

89

[55]

Alzada South American Colloid 

Company

56 – 65

[35 – 40]

72

[45]

BPM Colony Mill Bentonite Performance 

Minerals L.L.C.

71

[44]

151

[94]

BPM Colony Mine Bentonite Performance 

Minerals L.L.C.

71

[44]

151

[94]

BPM Montana Bentonite Performance 

Minerals L.L.C.

56 – 64

[35 – 40]

72

[45]

Colony East Mill American Colloid 

Company

71

[44]

151

[94]

Colony West Mill American Colloid 

Company

69

[43]

151

[94]

Oshoto Mine Black Hills Bentonite 5

[3]

8

[5]

Thornton Plant Black Hills Bentonite 56

[35]

69

[43]

12 Source: Wyoming State Mine Inspector, 2010; WDEQ, 2012; BLM, 2008; BLM, 2011 as cited in Strata, 2012a.

13

14 Oil and Gas Production 

15

16 Regional oil and gas development activities (e.g., exploration, production, and pipeline 

17 development) could have the potential to generate cumulative impacts (BLM, 2005b) when 

18 evaluated in conjunction with the Ross Project. There are approximately 472 oil and gas 

19 production units evenly dispersed throughout the Powder River Basin in various stages of 

20 production. The Wyoming Oil and Gas Conservation Commission reported that in 2003, oil and 
DRAFT Cumulative Impacts

5-12

1 gas wells in the Powder River Basin produced approximately 113 million barrels of oil and 1.1 

billion m3 [40 billion ft3 2 ] of conventional gas (BLM, 2005a; BLM, 2005b; BLM, 2005c). 

3

4 Most of Wyoming current oil production is from old oil fields with declining production and the 

5 level of exploration drilling to discover new fields has been low (BLM, 2005a). From 1992 to 

6 2002, oil production from conventional oil and gas wells in Campbell and Converse Counties 

7 within the Powder River Basin decreased approximately 60 percent. Oil- and gas-related 

8 development includes major transportation pipelines and refineries. In 2003, the cumulative 

9 disturbed land area in the Powder River Basin from oil and gas, coal-bed methane (CBM), and 

10 related development was nearly 76,081 ha [188,000 ac]. The corresponding projection for the 

11 year 2015 is 123,429 ha [305,000 ac] (BLM, 2005a; BLM 2005b; BLM, 2005c). The depth to 

12 producing gas and oil-bearing horizons generally ranges from 1,219 – 4,115 m [4,000 – 13,500 

13 ft], but some wells are as shallow as 76 m [250 ft] (BLM, 2005a; BLM, 2005b; BLM, 2005c). 

14

15 There are three oil-producing wells on the Ross Project area itself in addition to three oil-field 

16 water-supply wells and two injection wells. These are used for enhanced oil recovery (EOR) 

17 and were discussed during this SEIS’s evaluation of ground-water impacts in Section 4.5.1. 

18 Figure 3.2 indicates the locations of all of the oil- and gas-producing wells in a 3-km [2-mi] 

19 radius of the Ross Project area. 

20

21 Coal-Bed Methane Development

22

23 Natural gas production has been increasing in Wyoming. CBM is located where there are 

24 abundant coal resources. For this reason, the majority of CBM production in Wyoming occurs in 

25 the Powder River Basin. Annual CBM production in the Powder River Basin increased rapidly 

26 between 1999 and 2003, with nearly 15,000 producing CBM wells in the Powder River Basin in 

2003 and a total production volume of 10.3 billion m3 [364 billion ft3 27 ] (BLM, 2005a; BLM, 2005b; 

28 BLM, 2005c). However, there are no CBM-producing wells in the 80-km [50-mi] radius vicinity 

29 of the Ross Project area. This is because the local stratigraphy at the Ross Project area falls 

30 below the Wasatch and Fort Union Formations where CBM production occurs (Strata, 2012a). 

31

32 Wind Power Development 

33

34 While there is potential in the Powder River Basin for wind-power generation to contribute to 

35 meeting forecasted electric power demands, they are dependent on 1) the location of sage36 grouse core breeding areas and 2) available transmission capacity to send power to users. 

37 Both the location of Greater sage-grouse core breeding areas and transmission capability may 

38 be constraining factors (BLM, 2008; WOG, 2010). There are currently no wind power projects 

39 within the 80-km [50-mi] vicinity of the Ross Project area, and only one is proposed (see Figure 

40 5.1) (Strata, 2012a). 

41

42 This wind-power project, as proposed, would have a 250 MW capacity with 166 turbines 

43 generating approximately 600 million kWh annually (Strata, 2012a). It would be constructed 

44 and operated by Wind Energy America. This wind-power project would be located 

45 approximately 42 miles south-southeast of the Ross Project area, while it would be 

46 approximately 97 km [60 mi] to drive. It is south of I-90, where the Ross Project area is north of 

47 I-90.
DRAFT Cumulative Impacts

5-13

1 5.3 Cumulative Impacts Analysis

2

3 5.3.1 EISs as Indicators of Past, Present, and Reasonably Foreseeable Future Actions 

4

5 One indicator of present and reasonably foreseeable future actions (RFFAs) in a particular 

6 region of interest is the number of recent draft and final environmental-impact-statement (EIS) 

7 documents prepared by Federal agencies. The NRC used information in the GEIS, Section 

8 5.1.1, as well as publicly available information, several site-specific EISs and SEISs for projects 

9 in the Powder River Basin, and draft and final programmatic EISs for large-scale actions related 

10 to several states including Wyoming to accomplish its cumulative-impacts analyses (NRC, 

11 2009). 

12

13 5.3.2 Methodology

14

15 For the determination of potential cumulative impacts, the NRC staff reviewed Appendix F of the 

16 GEIS and determined that a Level 2 cumulative effects analysis was appropriate for this SEIS 

17 due to the fact that concerns were identified during the site-specific analysis (SEIS Section 4) 

18 with respect to the sustainability or quality of some of the resource areas within the uranium 

19 milling region (NRC, 2009). Therefore, the following methodology was developed, based on 

20 CEQ guidance (CEQ, 1997) for a Level 2 cumulative effects analysis as described in the GEIS 

21 (NRC, 2009): 

22

23 ■ Identify for each resource area the potential environmental impacts that would be of concern 

24 from a cumulative-impacts perspective. The impacts of the Proposed Action and the two 

25 Alternatives are described and analyzed by resource area in SEIS Section 4, Environmental 

26 Impacts and Mitigation Measures. 

27 ■ Identify the geographic scope for the analysis of each resource area. This scope is 

28 expected to vary from resource area to resource area, depending on the geographic extent 

29 of the potential impacts. 

30 ■ Identify the timeframe over which cumulative impacts would be assessed. The timeframe 

31 selected for this SEIS begins in approximately 2013, when the Applicant would receive a 

32 source material license from the NRC for the Ross Project, and includes any contemporary 

33 effects of past activities that persist at the Ross Project area. After receiving a license, the 

34 Applicant could begin facility construction and wellfield installation. After the NRC approves 

35 the Applicant’s definition of its target background values (for excursion detection and aquifer 

36 restoration), the Applicant could begin operation. In general, the cumulative-impact 

37 analyses timeframes terminate in 2027, which represents the projected license termination 

38 data at the end of the decommissioning period (see Figure 2.6 in SEIS Section 2.1.1). In 

39 some resource areas, however, the NRC’s analysis considers impacts beyond 2027 to the 

40 extent that some resources, such as ground-water resources, could require additional time 

41 to equilibrate after the complete decommissioning of the Ross Project.

42 ■ Identify past, existing, and anticipated future projects and activities in and surrounding the 

43 project area. These projects and activities are identified in this section. 

44 ■ Assess the cumulative impacts for each resource area from the Proposed Action and 

45 reasonable alternatives and other past, present, and reasonably foreseeable future actions. 
DRAFT Cumulative Impacts

5-14

1 This analysis would take into account the environmental impacts of concern identified in 

2 Step 1 and the resource area-specific geographic scope identified in Step 2. 

3

4 The following terminology was used to define the level of cumulative impact: 

5

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

7 neither destabilize nor noticeably alter any important attribute of the resource 

8 considered. 

9

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

11 important attributes of the resource considered. 

12

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

14 destabilize important attributes of the resource considered. 

15

16 In conducting this assessment, NRC staff recognized that for many aspects of the activities 

17 associated with the proposed Ross Project, there would be SMALL impacts on affected 

18 resources. It is possible, however, that an impact that may be SMALL by itself, but could result 

19 in a MODERATE or LARGE cumulative impact when considered in combination with the 

20 impacts of other actions on the affected resource. Likewise, if a resource is regionally declining 

21 or imperiled, even a small individual impact could be important if it contributes to or accelerates 

22 the overall resource decline. The NRC staff determined an appropriate level of analysis that 

23 was merited for each resource area potentially affected by the Proposed Action and 

24 alternatives. The level of detailed analysis was determined by considering the impact level to 

25 that resource, as described in SEIS Section 4, as well as the likelihood that the quality, quantity, 

26 or stability of the given resource could be affected. 

27

28 The subsequent sections document the NRC’s cumulative impact analyses in the following 

29 areas:

30

■ Land Use

■ Transportation

■ Geology and Soils

■ Water Resources

■ Ecology

■ Air Quality

■ Global Climate Change and 

Greenhouse-Gas Emissions 

■ Noise

■ Historical, Cultural, and

Paleontological Resources

■ Visual and Scenic Resources

■ Socioeconomics

■ Environmental Justice

■ Public and Occupational 

Health and Safety

■ Waste Management

31 5.4 Land Use

32

33 The geographic area within which cumulative impacts to land use were evaluated were Crook 

34 and Weston counties, which are within the BLM’s Newcastle Field Office planning area, and 

35 Campbell County, which is within the planning area administered by the BLM Buffalo Field 

Office (see Figure 2.1 in SEIS Section 2). These three counties include over 26,000 km2 36

[10,000 mi2

] and incorporate the approximately 42 km2 [25 mi2 37 ] of the Ross Project area. These 
DRAFT Cumulative Impacts

5-15

1 three counties serve as the geographic boundary area where socioeconomic factors that could 

2 relate to land use (i.e., within commuting distance, within shopping distance, and/or within 

3 lodging or new home construction distance) would occur. This area is referred to in this section 

4 as the “land-use cumulative-impacts study area.” Thus, the Ross Project would be 

5 approximately 1/4 of 1 percent of the entire land-use cumulative-impacts study area. The 

6 timeframe for this cumulative-effects analysis is from 2013, when the Applicant could be issued 

7 a license by the NRC, through 2027, when the Ross Project would be completely 

8 decommissioned and the aquifers would have been restored. 

9

10 Land use within the Powder River Basin is diversified and cooperative, with CBM as well as oil 

11 and gas extraction activities sharing the land with livestock. Although Federal grasslands and 

12 forests cover approximately 21 percent of the Powder River Basin area, most rangeland is 

13 privately owned (68 percent) and is used primarily for grazing cattle and sheep. In Crook 

14 County, the land ownership is also primarily private. Within Campbell County, however, land 

15 ownership is primarily Federal and is allocated by BLM for use as pasture (see Figure 5-5).

16

17 As noted in SEIS Section 3.2, the land-use impacts of the Ross Project would result primarily in 

18 the interruption, reduction, or impedance of livestock grazing and wildlife habitat; there is not 

19 public access to the area generally (e.g., for hunting or fishing) nor is there significant 

20 agriculture occurring currently at the Ross Project area (see Table 2.1 in SEIS Section 2.1.1). 

21 There are no longer any impacts from historical operations at the Ross Project area (i.e., 

22 Nubeth.) In addition, the area that would be disturbed by the Ross Project encompasses a total 

23 of 113 ha [280 ac] of land, which represents 16 percent of the Ross Project area. The 

24 permanent impacts of the Ross Project would be limited, because the Applicant would be 

25 required to return the land to the post-licensing, pre-operational conditions described in SEIS 

26 Section 2.1.1.2, unless the respective landowners wish to have certain roads, for example, 

27 remain. Thus, the potential land-use impacts from the Ross Project would be temporary and 

28 SMALL through all of its phases, as discussed in SEIS Section 4.2. 

29

30 Mining in the form of coal, mineral, oil, and gas production are all important land uses of the 

31 cumulative-impacts study area. As noted Section 5.2, both conventional and CBM oil and gas 

32 production are expected to continue in upcoming years. As of 2010, there were over 2,600 

33 conventional oil- and gas-well permits in the land-use cumulative-impacts study area (USGS, 

2011), with 889 producing wells (or less than 1 producing well per 26 km2 [10 mi2 34 ]. A typical 

35 drilling location, including the access road, disturbs approximately 1.11 ha [2.75 ac] of land; at a 

density of 1 well per 26 km2 [10 mi2 36 ], this would represent up to 0.04 percent of the land affected 

37 by these wells. In addition, over 1,570 of the permitted wells have been abandoned and are no 

38 longer being used. Through 2008, 547 CBM wells had been drilled within the three-county 

study area (or approximately one producing well per 52 km2 [20 mi2 39 ], affecting approximately 

40 0.02 percent of the total land area) (USGS, 2011). Because of the small area of impact for each 

41 well and the moderate number of wells currently being operated, the cumulative impacts of the 

42 use of land for oil and gas production is SMALL.

43

44 As noted in Section 5.2, coal production in the Wyoming portion of the Powder River Basin is 

45 expected to grow at an annual rate of 2 – 3 percent per year. It is predicted that from 2010 to 

46 2020, the land area impacted by coal development in the Powder River Basin will increase from 

47 39,927 ha – 55,621 ha [98,662 ac – 137,443 ac]. By 2020, these impacts would represent 1.3 

48 percent of the land in the Powder River Basin. However, most of this coal-mining growth would 
DRAFT Cumulative Impacts

5-16

1 be in the central area of Campbell County and in an area where the nearest coal mine is over 

2 45 km [28 mi] from the Ross Project area. In the 80-km [50-mi] area shown in Figure 5.1, there 

3 are 9 operating coal mines (Strata, 2012a). This coal-mining land use has and would continue 

4 to have a MODERATE impact in the land-use cumulative-impacts study area.

5

6 There are no operating nor licensed ISR facilities within 83 km [50 mi] of the Ross Project, 

7 although there are four uranium-recovery projects in the very early stages of development as 

8 described in SEIS Section 5.2 (i.e., Aladdin, Elkhorn, Hauber and Altzada). There is also a 

9 potential for development of other uranium facilities to the south of the Ross Project as part of 

10 the entire Lance District as described earlier. Thus, some land-use changes as a result of these 

11 reasonably foreseeable future developments could occur. To assess the projected land area 

12 that would be affected by the development of these present and foreseeable future actions, the 

13 NRC staff assumed that approximately the same area affected by the Ross Project and its 

14 disturbance of 113 ha [280 ac] would also be approximately the same as by these other ISR 

15 projects. Using this assumption, the NRC estimated that the four other non-Strata projects and 

16 the four other Strata Lance District projects would impact an additional 904 ha [2,240 ac], for a 

17 total area disturbed by potential ISR projects in the land-use cumulative-impacts study area of 

18 1,017 ha [2,520 ac]. This acreage accounts for only approximately 0.04 percent of the total 

19 study area. Therefore, these ISR projects would have a SMALL impact on land use.

20

21 The NRC staff has concluded that the cumulative impacts on land use in the study area 

22 resulting from past, present, and reasonably foreseeable future actions is MODERATE. The 

23 Ross Project would have a SMALL incremental effect on land use when added to the 

24 MODERATE cumulative land-use impacts. 

25

26 5.5 Transportation

27

28 An area with an 80-km [50-mi] radius was used as the geographic boundary in the evaluation of 

29 the cumulative impacts of transportation for this SEIS (referred to in this section as the 

30 “transportation cumulative-impacts study area”). This study area was selected because it 

31 incorporates the area that would likely be used by the majority of the workers at the Ross 

32 Project and includes the distance to the nearest Interstate highway (i.e., Interstate-90). The 

33 analysis of transportation-related cumulative impacts is the timeframe of 2013 – 2027, which 

34 would be the entire lifecycle of Ross Project from licensing to final decommissioning. The 

35 analysis assumes that within this timeframe the four potential satellite areas within the Lance 

36 District would be developed sufficiently by the Applicant to begin construction and operation.

37

38 The environmental impacts identified in SEIS Section 4.3.1 for the Ross Project would result 

39 from the transport of chemical supplies, building materials, yellowcake product, vanadium 

40 product, solid byproduct wastes, other hazardous and nonhazardous wastes, and the 

41 commuting workforce, all of which increase traffic volumes to and from the Ross Project area. 

42 During the phases of the Ross Project examined in SEIS Section 4.3, traffic volume was 

43 estimated to increase up to 200 percent. This traffic would predominantly be present on the 

44 local Crook County roads. As a result, the wear and tear of the county roads would be 

45 significantly increased, and the potential for wildlife mortality and vehicular accidents would 

46 increase as well. Therefore, the transportation impacts were found to be SMALL TO LARGE, 

47 as discussed in Section 4.3. With the mitigation measures discussed in Section 4.3, the

48 transportation impacts would be reduced to SMALL to MODERATE. Once the Ross Project is 
DRAFT Cumulative Impacts

5-17

1 decommissioned, most wellfield roads constructed as part of the Ross Project would be 

2 removed, and the traffic volume would subside to a little more than the 2010 volume. 

3

4 Direct impacts to the roads and highways within the transportation cumulative-impacts study 

5 area include increased vehicular-traffic volumes and increased risk of vehicular accidents during 

6 daily commutes by workers and the trips their families take, especially on roads such as New 

7 Haven and D Roads. Ross Project workers would use these roads as would workers from the

8 Lance District satellite areas and two of the five potential ISR projects currently being planned. 

9 If the same workforce is assumed for the two other potential ISR projects; if they are assumed 

10 to be under construction at the same time; and if it is assumed that the workers at both the 

11 Elkhorn and Hauber projects were to use D or New Haven Roads to commute to and from work, 

12 this would increase D and New Haven Roads traffic to approximately and conservatively 920 

13 additional automobiles on this road alone per day (it was assumed here that the Ross Project 

14 would be already in its operation phase and its workforce would have been reduced to 60 

15 workers). In addition, all of the supply and materials deliveries during their construction phase 

16 and uranium-product shipments would need to be added to this traffic volume. The volume that 

17 results, assuming the same number of deliveries and shipments by the other ISR projects would 

18 rise to almost 1,000 vehicles per day. (Also, D Road is already being used by the Oshoto 

19 bentonite mine northeast of the Ross Site area, although there are only a reported eight workers 

20 currently commuting to that facility; consequently, this traffic was already considered under the 

21 Ross Project’s transportation impacts in SEIS Section 4.3.) This would be a LARGE cumulative 

22 impact for D and New Haven Roads. Traffic on I-90 is expected to be similarly increased during 

23 this period. However, the Interstate highway has been designed to provide sufficient capacity 

24 for this increase (as discussed in SEIS Section 4.3). Thus, the transportation impacts on the 

25 Interstate-highway system of the U.S. would be SMALL. 

26

27 All of indirect impacts identified for the proposed Ross Project, including increased wear and 

28 tear on existing roads, air emissions, fugitive dusts, noise, and risk of vehicle collisions with 

29 livestock, wildlife, and other vehicles, would occur as a result of this increased traffic volume on 

30 the county roads. This would be a MODERATE to LARGE impact.

31

32 The NRC staff has concluded that the cumulative impacts within the study area resulting from 

33 past, present, and reasonably foreseeable future actions is MODERATE to LARGE. The

34 proposed Ross Project would have a SMALL to MODERATE incremental effect on 

35 transportation when added to the MODERATE to LARGE cumulative transportation impacts.

36

37 5.6 Geology and Soils

38

39 The geographic area for the evaluation of geology and soils cumulative impacts (“geology and 

40 soils cumulative-impacts study area”) is defined as the approximately 9,000-ha [22,200-ac] 

41 Lance District shown on Figure 2.2 in SEIS Section 2.1.1. Limiting the cumulative impacts 

42 assessment for soils to this area is appropriate since geology and soil impacts are limited to the 

43 area in which they occur. The Ross Project itself would result in the disturbance of 113 ha [280 

44 ac] of surface soil, a very small fraction of the total study area (i.e., approximately 0.013 

45 percent). 

46

47 Previous ISR activities at the Ross Project site include research and development activities 

48 conducted by Nubeth in the late 1970’s. These activities included construction and operation of
DRAFT Cumulative Impacts

5-18

1 a small 5-spot wellfield for one year that likely resulted in some soil disturbance to a small area 

2 of land (Strata, 2011a). Regulatory approval of Nubeth’s decommissioning was granted by 

3 1986. The Nubeth area was restored and these past activities are consequently no longer 

4 relevant for the geology and soils cumulative impacts analysis.

5

6 As noted in Section 5.3.2, the proposed schedule for construction, operation, and 

7 decommissioning as well as the restoration of the aquifer(s) at the Ross Project show activities 

8 taking place over an approximate nine-year period from the time the Project would be licensed 

9 by the NRC (Strata, 2012a). The other Lance District wellfield-development activities (i.e., 

10 satellite areas) could extend the processing of loaded IX resins at the Ross Project’s CPP by 

11 another five years or more (Strata, 2012a) to 2027 (see Figure 2.6 in Section 2.1.1). However, 

12 the geology and soils impacts within the Ross Project area where the soils would have been 

13 disturbed would need additional time to recover. These impacts would dissipate quickly once 

14 site restoration is complete, within five years or less; therefore, the time period for this geology 

15 and soils cumulative-impacts evaluation is 19 years from the licensing of the Ross Project, or

16 the year 2032.

17

18 During the lifecycle of the Ross Project, as discussed in SEIS Section 4.4, potential impacts to 

19 Ross Project area geology would be predominantly associated with drillholes, wells, and 

20 wellfields. At the conclusion of the Ross Project, an average density of approximately 4.3 

21 wells/ha [1.7 wells/ac], each properly plugged and abandoned, would remain. The Applicant’s 

22 proper plugging and abandoning of these holes would mitigate their impact vis-à-vis the local 

23 geology. Also, the records required by the Applicant’s permits for well plugging and 

24 abandonment would allow a final assessment of geology impacts after the Ross Project has 

25 been decommissioned, if necessary. 

26

27 The most significant impacts for soils would be soil loss and compaction, soil-productivity loss, 

28 and potential soil contamination. There would also be soil disturbance associated with the 

29 construction of the CPP, surface impoundments, and access roads as well as pipeline and 

30 wellfield installation. Accidental releases of drilling fluids and muds, process solutions, and 

31 other liquids could cause soil contamination throughout the Project’s lifecycle. As noted in SEIS 

32 Section 4.4, facility- and wellfield-design features, best management practices (BMP), and 

33 permit requirements, such as the Applicant’s Permit to Mine, UIC, and Wyoming Pollution 

34 Discharge Elimination System (WYPDES) Permits would minimize these potential impacts 

35 during the Ross Project’s construction, operation, aquifer restoration, and decommissioning. 

36 The Project’s decommissioning would include reclamation of soils and the restoration of the site 

37 to baseline conditions. Baseline conditions have been documented by soils and vegetation 

38 surveys of the Ross Project area. The surveys have established a baseline conditions against 

39 which soils impacts at the Ross Project can be measured (see Figure 3.10). 

40

41 Thus, the geology and soil impacts of the Ross Project would be SMALL in the geology and 

42 soils cumulative-impact study area.

43

44 To assess cumulative impacts to soils, the area of soil disturbances need to be quantified. The 

45 Applicant has identified four potential ISR satellite areas within the Lance District (see Figure 

46 2.2 in SEIS Section 2.1.1) (Strata, 2012a). The NRC assumed that each of these satellite areas 

47 would require the same area of soil disturbance as the Ross Project; thus, their development 

48 would result in 450 ha [1,120 ac] of soil disturbance. The density of wells at the satellite 
DRAFT Cumulative Impacts

5-19

1 facilities would be similar to the density at the Ross Project. The impacts to geology and soils 

2 would be mitigated as those at the Ross Project would, including complete site reclamation at 

3 the end of the Project’s lifecycle. If the density of drillholes and wells at these areas would be 

4 the same as the Ross Project, and the requirements for plugging and abandonment of the holes 

5 would be the same, the potential impacts to geology and soils at each satellite facility would be 

6 generally equivalent to those of the Ross Project, which were determined to be SMALL.

7

8 As shown on Figure 5.1, there are numerous oil and gas fields that are located within the Lance 

9 District. There are no publicly announced plans for further oil and gas development in the area. 

10 The impacts to local geology would be the depletion of the oil and gas resources and the 

11 remaining, plugged wells after production. For soils, the current wells and any future wells 

12 would cause soil impacts due to the drilling of recovery wells, constructing new roads, and 

13 conducting other operating activities. These soil impacts would also be required to be mitigated 

14 with site-specific BMPs and site-restoration requirements. 

15

16 The NRC staff has determined that the cumulative impacts to geology and soils in the geology 

17 and soils cumulative-impacts study area would be SMALL. The soil disturbance associated with 

18 the Ross Project area and the other satellite projects in the Lance District would be limited to 

19 approximately 5 percent of the approximately 9,000-ha [22,200-ac] Lance District with 95 

20 percent of the area remaining undisturbed. This disturbance to geology and soils would be 

21 dispersed throughout the Lance District and site restoration would be required. The proposed 

22 Ross Project would have a SMALL incremental impact on the SMALL cumulative impacts to 

23 geology and soils in the geology and soils cumulative-impacts study area. 

24

25 5.7 Water Resources

26

27 The analysis of the cumulative impacts to both surface and ground waters are described below.

28

29 5.7.1 Surface Water

30

31 The geographic area for the evaluation of surface-water cumulative impacts has been defined 

32 as Little Missouri River Basin, from the Ross Project downstream to the Wyoming/Montana 

33 border (see Figure 3.10 in SEIS Section 3.4.2). Within this stretch of the Little Missouri River, 

34 which begins in within the Ross Project area, the mean flow increases from an average of less 

than 0.05 m3

/s [1.7 ft3 35 /s] at SW-1, near the downstream Ross Project boundary, to an average 

of 2 m3

/s [77 ft3 36 /s] just downstream of the Wyoming/Montana border. The 45-fold increase in 

37 flow within 80 km [50 mi] indicates that cumulative impacts associated with the Ross Project 

38 could only be measured in the upper reaches of the Little Missouri River Basin, which is why 

39 this geographic area was selected for cumulative-impacts analysis. As the River’s flow 

40 substantially increases downstream of the Ross Project, any cumulative impacts would be 

41 lessened by the additional volume of water.

42

43 As discussed in Section 5.3.2, the timeframe defined for the cumulative-impact analysis is 14 

44 years after license issuance. The schedule shown in Figure 2.6 in SEIS Section 2.1.1 indicates 

45 that the construction, operation, aquifer restoration, and decommissioning of the Ross Project 

46 facility and wellfields would take place during this time period. Since the impacts of the Ross 

47 Project on surface-water flows and surface-water quality would dissipate quickly upon 
DRAFT Cumulative Impacts

5-20

1 completion of the decommissioning phase, this cumulative-impact analysis for surface water 

2 ends at 2027 after final Ross Project decommissioning is complete.

3

4 The Ross Project would use surface water from the Little Missouri River for dust control and 

5 construction-related activities. The Applicant would need to obtain a WYPDES Permit for storm6 water management and for the discharge of ground water from wells outside the exempted ore7 zone aquifer during the Ross Project’s lifecycle. As described in SEIS Section 4.5.1, the 

8 impacts to surface-water quantity would be minimal, and the potential water-quality impacts 

9 would be mitigated by BMPs, management plans, and permit requirements. The potential 

10 impacts of erosion in the small area of temporary land disturbance as well as from accidental 

11 process-solution and other liquid spills and leaks would be localized and short-term because of 

12 the management plans and standard operating procedures (SOPs) the Applicant would adopt. 

13 The potential impacts to the surface-water quantity and quality from the Ross Project would be 

14 SMALL. 

15

16 With respect to wetlands, the Ross Project’s construction would have the potential to impact up 

17 to 0.8 ha [2 ac] of wetlands. A USACE-required permit would oblige the Applicant to provide a 

18 site-specific mitigation plan for all Project-related disturbance of jurisdictional wetlands. This 

19 plan would ensure that appropriate mitigation measures would be in place so that there is no net 

20 loss of wetlands. As described in SEIS Section 4.5.1, the Ross Project’s potential impacts to 

21 wetlands would be SMALL.

22

23 Measurements of pre-licensing baseline surface-water flows and baseline water-quality 

24 parameters provide the baseline characteristics for assessment of cumulative impacts to 

25 surface-water quantity and quality (Strata, 2011a). The monitoring program that the Applicant

26 would implement during all phases of the Ross Project would ensure that the Applicant meets 

27 NRC license conditions and WDEQ/Land Quality Division’s (LQD’s) Permit to Mine 

28 requirements. This monitoring program is discussed in SEIS Section 6.

29

30 The cumulative impacts for surface water would be related to water quantity and water quality. 

31 All streams within the upper reaches of the Little Missouri River and for 67 km [40 mi] 

32 downstream of the Ross Project are classified by WDEQ/Water Quality Division (WQD) as 3B 

33 streams (i.e., intermittent or ephemeral stream incapable of supporting fish populations or 

34 providing drinking water). At the confluence with Government Canyon Creek (approximately 67 

35 km [40 mi] downstream of the Ross Project area), the River’s flow increases to the point that the 

36 stream classification changes to 2ABWW (i.e., it is protected as a drinking-water source and can 

37 support warm-water fisheries). Surface-water quality in the upper reaches of the Little Missouri 

38 River currently meet Wyoming’s surface-water criteria for a Class 3B stream (Strata, 2011a). 

39 Current surface-water flows would define the baseline conditions against which impacts can be 

40 measured over time. Data on surface-water flows are available from three monitoring stations 

41 within the Ross Project area for 2010 and 2011 (Strata, 2012a). These data, combined with 

42 flow data from the Wyoming/Montana border would provide a dataset against which changes in 

43 surface-water flow can be evaluated. 

44

45 Surface-Water Quantity

46

47 Strata’s potential uranium-recovery satellite areas in the Lance District, as described in SEIS 

48 Section 5.2, could impact the Little Missouri River (Strata, 2012a). Of the four identified 
DRAFT Cumulative Impacts

5-21

1 potential satellite areas, only the Ross Amendment Area 1 lies within the Little Missouri River 

2 Basin. The others are located within the drainage basin of the Belle Fourche River. However, 

3 because the uranium-recovery and water-treatment from the satellite areas would continue to 

4 occur at the Ross Project’s CPP, these areas are considered in this evaluation of surface-water5 quality cumulative impacts, later.

6

7 Crop irrigation and stock watering are the primary uses of surface water in the Wyoming portion 

8 of the Little Missouri River Basin (WWDC, 2002a). Irrigation use is estimated to range from 

9 1,200 ha-m [9,700 ac-ft] to 1,400 ha-m/yr [11,600 ac-ft/yr] and evaporative loss from stock 

10 reservoirs is less than approximately 120 ha-m/yr [1,000 ac-ft/yr] (WWDC, 2002a). There are 

11 no other significant uses of surface water in the Wyoming portion of the Little Missouri River. 

12 The high estimate of current surface-water use is approximately 22 percent of the mean annual 

13 flow in the Little Missouri River at the Wyoming/Montana border (6,900 ha-m/yr [55,800 ac14 ft/yr]). Agricultural uses of surface water in the northeastern portion of Wyoming are estimated 

15 to grow between 0 and 9 percent, or an increase up to 140 ha-m/yr [1,130 ac-ft/yr], over the 

16 next 30 years (WWDC, 2002a).

17

18 During the lifecycle of the Ross Project, the annual surface-water use for construction and dust 

19 control is estimated to range from 0.71 ha-m/yr [5.8 ac-ft/yr] to 4.6 ha-m/yr [37 ac-ft/yr]. If the 

20 Ross Amendment Area 1 were to be permitted and developed concurrently with the Ross 

21 Project, and if it were to use a similar quantity of water for construction and dust control, 

22 surface-water use would double. However, the potential for increasing water-quantity impacts 

23 would continue to be mitigated by BMPs, management plans, and permit requirements. The 

24 remaining Lance District potential uranium-recovery areas are expected to rely upon surface 

25 water from outside the Little Missouri River Basin. 

26

27 Other projects that could potentially affect surface-water use within the surface-water 

28 cumulative-impacts study area (i.e., the Little Missouri Basin within Wyoming) are described as 

29 follows.

30

31 ■ Oshoto Mine: Bentonite mining typically does not use surface water. Water quality could 

32 be impacted by sediments, due to erosion and runoff (see Water Quality below) (BLM, 

33 2011).

34

35 The two uranium-recovery projects that have been identified for potential development within 

36 the Little Missouri River Basin are the Hauber and Elkhorn projects. Because there are no 

37 existing plans for these projects, the amount of surface water usage is unknown. However, the 

38 quantity of uranium targeted by each project has been used to scale and calculate the 

39 approximate water use by each, based upon the quantity of uranium reported to occur at each 

40 site. 

41

42 ■ Hauber Uranium Project: This project targets approximately 1.5 million pounds of U3O8, 

43 approximately 12 – 25 percent of the 3 – 6 million pounds targeted by the Ross Project. 

44 Thus, this project could use between 12 – 25 percent of the surface water the Ross Project 

45 would use. 

46 ■ Elkhorn Uranium Project: This project targets approximately 1.2 million pounds of U3O8, 

47 approximately 10 – 20 percent of the 3 – 6 million pounds targeted by the Ross Project. 
DRAFT Cumulative Impacts

5-22

1 This project would use between 10 – 20 percent of the surface water as the Ross Project 

2 would use. 

3

4 The numerous oil- and gas-recovery projects identified in Figure 5.1 have been assumed to rely 

5 upon ground water for water supply and are not expected to impact surface-water quantity. In 

6 addition, the projected changes in agricultural and industrial uses of surface water over the next 

7 14 years are predicted to increase surface-water use of the Little Missouri River from 22 percent 

8 to approximately 24 percent of the total flow in the Little Missouri River. Agriculture would 

9 account for about 1.8 percent increase. The two areas that the Applicant could develop (i.e., 

10 the Ross Project and the Ross Amendment Area 1) and the two other planned uranium11 recovery projects, the Hauber and Elkhorn projects, all in the Little Missouri Basin, would 

12 account for a 0.2 percent increase over the current use. Thus, the cumulative impact, a two13 percent decline in the flow of the Little Missouri at the Wyoming/Montana border, due primarily 

14 to an increase of agricultural withdrawals over the next 14 years, is small. In addition, the 

15 reduction in flow due to uranium-recovery projects would be short-term and minor compared to 

16 agricultural use. Thus, surface-water cumulative-impacts related to water quantity would be 

17 SMALL.

18

19 Surface-Water Quality

20

21 The water quality at the Ross Amendment Area 1 and the two uranium-recovery projects 

22 described above would also be protected by BMPs, management plans, and permit 

23 requirements. Increases in sediment and other water-quality parameters from uranium-recovery 

24 projects and other mining (bentonite) activities would be mitigated by the owner/operator 

25 implementing BMPs and management plans as well as complying with WYPDES Permits, 

26 WDEQ/LQD Permits to Mine, and NRC’s license conditions that would be included if a license 

27 amendment for this satellite were to be issued to the Applicant. Increases in impacts to water 

28 quality from agriculture would be mitigated through compliance with Wyoming’s Watershed 

29 Protection Program. Thus, the cumulative impacts to surface-water quality in the Little Missouri 

30 River Basin would be SMALL.

31

32 The cumulative impacts to water quantity and quality in the upper reaches of the Little Missouri 

33 River would be SMALL. The proposed Ross Project would contribute SMALL incremental 

34 impacts to the SMALL cumulative impact. 

35

36 5.7.2 Ground Water

37

38 The geographic area for the cumulative-impact analysis of ground-water impacts was based 

39 upon the hydrogeology of the Lance and Fox Hills Formations within the Powder River Basin, 

40 the practical maximum depth for water-supply wells, and the availability of ground-water sources 

41 as alternatives to the Lance and Fox Hills Formations. As described in SEIS Section 3.5.3, the 

42 ore zone at the Ross Project area is within the lower interval of the Lance Formation and upper 

43 interval of the Fox Hills Formation, which are separated from the aquifers above and below by 

44 confining units. NRC’s evaluation of cumulative effects is therefore limited to only the 

45 stratigraphic horizon targeted by the Ross Project, because the ore-zone aquifer is not in 

46 contact with aquifers above and below it. 
DRAFT Cumulative Impacts

5-23

1 The Black Hills Monocline east of the Ross Project area brings the Lance and Fox Hills 

2 Formations to outcrop. Recharge occurs primarily in the area of outcrop and where the 

3 Formations are directly below alluvium-filled drainages. The geographic extent for the “ground4 water cumulative-impacts analysis study area” is therefore delimited by the extent of the outcrop 

5 of the Fox Hills Formation to the east and by the 0 m [0 ft] elevation contour of the top of the Fox 

6 Hills Formation to the west. Along the other Ross Project boundaries, the geographic extent is 

7 defined by the 80-km [50-mi] radius from the Ross Project.

8

9 The schedule for construction, operation, aquifer restoration, and decommissioning at the Ross 

10 Project indicates a period of 14 years, from the licensing of the Ross Project to its complete 

11 decommissioning (see Figure 2.6 in SEIS Section 2.1.1) (Strata, 2012a). Ground-water 

12 modeling demonstrates that 10 years after restoration is complete, ground-water levels would 

13 have nearly recovered to a pre-uranium-recovery state (Strata, 2011b). Thus, the time period of 

14 24 years from the start of the Ross Project was defined for this cumulative-impacts evaluation 

15 (i.e., the year 2037). The Applicant estimates that recharge to the Lance Formation would be 

16 between 0.03 to 0.09 cm/yr [0.07 and 0.22 in/yr] (Strata, 2011b). Because of the limited Lance 

17 and Fox Hills Formations recharge area and their low recharge rates, small residual drawdowns 

18 in the vicinity of the Lance District would likely be present for tens of years after cessation of 

19 uranium-recovery activities.

20

21 The primary cumulative impacts for ground water would be related to both water quantity and 

22 water quality. During uranium-recovery at the Ross Project, there would be a net withdrawal of 

23 water from the ore-zone aquifer. This withdrawal rate would produce decreases in ground24 water levels in Ross Project wellfields. Other ground-water users that operate wells completed 

25 in the same hydrostratigraphic unit would also affect water levels in the vicinity of their wells. 

26 Extraction of ground water in excess of the rate of recharge to the aquifer in the same 

27 hydrostratigraphic unit would result in the decline in ground-water levels with time. Upon 

28 termination of water extraction, however, recharge of the aquifer would then increase ground29 water levels. As described in SEIS Section 4.5.1, the potential impacts to the ground-water 

30 quantity from the Ross Project would be SMALL as its consumptive use would be mitigated by 

31 alternative water supplies as necessary.

32

33 Data on ground-water levels and water-quality data are available for a number of wells within 

34 the Ross Project area from early 2010 (Strata, 2011a; Strata, 2011b; Strata, 2012a). These 

35 data, together with individual wellfield post-licensing, pre-operational baseline data that would 

36 be required as part of the NRC license, would provide a dataset against which changes in 

37 ground-water quality can be evaluated. Long-term observations of ground-water levels and 

38 ground-water monitoring within the hydrostratigraphic unit would provide a metric for assessing 

39 the cumulative ground-water quantity impacts. The monitoring program proposed by the 

40 Applicant to meet NRC and WDEQ/LQD Permit to Mine requirements are discussed in SEIS 

41 Section 6.

42

43 At the Ross Project area, ground-water flow is to the northwest, into the Powder River Basin. 

44 The top of the Fox Hills Formation is at approximately an elevation of 1,100 m [3,600 ft] in the 

45 area of the Ross Project. A review of ground-water resources in the Powder River Basin notes 

46 that ground-water quality and drilling economics generally limit the maximum depth of wells to 

47 less than 300 m [1,000 ft] (WWDC, 2002b). However, the City of Gillette does have wells 

48 approximately 1,050 – 1,350 m [3,500 – 4,500 ft] deep, tapping the Fox Hills Formation where 
DRAFT Cumulative Impacts

5-24

1 the top of the Fox Hills Formation is at an elevation 150 m [500 feet] (WSGS, 2012). At this 

2 location, the high total dissolved solids (TDS) in the ground water requires it be mixed with 

3 waters from deep wells, which are located near Moorcroft; they are drilled into the Madison 

4 Formation, where fewer TDSs are present. Because both the depth to the Fox Hills Formation 

5 and the fact that TDS concentrations increase farther into the Powder River Basin, the municipal 

6 water-supply wells for Gillette mark the westernmost practical limit for extraction of potable 

7 water from the Ross Project’s ore-zone aquifer. Therefore, the western edge of the ground8 water area defined for cumulative-impact analysis is the 0 m [0 ft] structural contour, on the top 

9 of the Fox Hills Formation, which is located about 60 km [37 mi] west of the Ross Project area. 

10 At this point, the Fox Hills aquifer is approximately 1,200 – 1,500 m [4,000 – 5,000 ft] deep. 

11

12 During the operation and aquifer-restoration phases of the Ross Project, the weighted average 

13 ground-water consumption has been estimated to be 462 L/min [122 gal/min] over a period of 6 

14 years (Strata, 2011a). The Ross Project area has a predicted U3O8 production of 340,000 kg/yr 

15 [750,000 lb/yr] over 4 – 8 years, and the Ross Amendment Area 1 would extend this rate of 

16 production for several years (Strata, 2012a). Production would rise to 993,000 kg/yr [2.19 

17 million lb/yr] U3O8 (i.e., yellowcake) with the Kendrick, Richards and Barber satellite areas. If 

18 consumptive water use is assumed to be proportional to U3O8 production, then ground-water 

19 consumption would increase to an average of 1,347 L/min [356 gal/min] over the period of 

20 maximum production within the Lance District. It is likely that ground-water drawdowns at the 

21 uranium-recovery wellfields in the Lance District would overlap both spatially and temporally. 

22

23 As noted earlier, the Wyoming State Engineer’s Office (SEO) maintains a database of ground24 water rights, including water use, well yield, well location, and well depth; however, the geologic 

25 interval from which the ground water is extracted is not recorded. Furthermore, data on the 

26 yield may not be representative of the actual volumes pumped. Thus, the current rate of 

27 ground-water withdrawal from the Lance and Fox Hills formations, and in particular the ore-zone 

28 interval, cannot be estimated. The Applicant reviewed the Wyoming SEO’s database and 

29 concluded that most of the permitted stock and domestic wells within the region of the Ross 

30 Project were completed within the Lance Formation sandstones above the ore zone and were 

31 not in hydrologic communication with the ore zone. The depth of the ore zone, typically greater 

32 than 120 m [400 feet], and the fact that there are other aquifers above the ore zone would make 

33 the ore-zone (OZ) aquifer unattractive as a ground-water source (Strata, 2011b). In addition, 

34 any future ground-water development of the Lance and Fox Hills aquifer system would be 

35 localized and limited, due to poor water quality (WWDC, 2002a). 

36

37 There are a number of existing or potential resource-extraction projects within the ground-water 

38 cumulative-impacts study area that have water demands. These are:

39

40 ■ Uranium Recovery: Other existing or planned uranium-recovery projects are outside the 

41 specific geographic area selected for ground-water-related cumulative-impact analysis, and

42 are in a different stratigraphic horizon than is the Ross Project (Strata, 2012a). The planned 

43 Aladdin, Elkhorn, Hauber, and Alzada uranium-recovery projects, if they come to fruition, 

44 would target uranium in the Fall River and Lakota Formations. These Formations are of 

45 lower Cretaceous age, located several thousand feet below the Lance and Fox Hills 

46 Formations, and are separated by the thick Pierre Shale. Thus, uranium-recovery activities 

47 in those Formations would not impact the same ground water at the Ross Project.
DRAFT Cumulative Impacts

5-25

1 ■ Coal Mining and CBM Extraction: The mining of coal and extraction of CBM occur along 

2 the western margin of the geographic area (see Figure 5.1). The principal coal seams are in 

3 Tongue River Member of the Fort Union Formation, which is separated from the Lance and 

4 Fox Hills Formations by several thousand feet of the Upper Hell Creek and Lebo confining 

5 units (Hinaman, 2005). Ground-water pumping associated with CBM production, coal 

6 mining and processing, and mine-mouth power generation would therefore not impact 

7 ground water within the Lance and Fox Hills Formations.

8 ■ Bentonite Mining: Bentonite-mining operations take place in the shale intervals 

9 stratigraphically below the Lance and Fox Hills Formations and are, therefore, outside the 

10 geographic area for the analysis of ground-water cumulative impacts. 

11 ■ Other Mining: Other potential mining projects, for example, the Bear Lodge Rare Earth 

12 project, are also outside the geographic area defined for ground-water cumulative impacts.

13 ■ Oil Recovery: In the mature oil fields of northeast Wyoming, water is used for EOR and is 

14 described as “water flooding” (De Bruin, 2007). At the Ross Project area, the Lance and 

15 Fox Hills aquifers show approximately 46 m [150 ft] of drawdown due to withdrawals by the 

16 three water-supply wells that have been used since 1980 for oil production (see SEIS 

17 Section 4.5.1) (Strata, 2011b). The oil-field water-supply wells within the cumulative-impacts 

18 study area would continue to be used during the period of active uranium recovery at the 

19 Ross Project. Only a portion of the water requirements, however, would be provided by the 

20 Lance and Fox Hills Formations, as stratigraphically higher aquifers are available in the 

21 western portion of this area. 

22

23 Ground-Water Quantity

24

25 The NRC staff has determined that the cumulative impacts to ground-water quantity in the 

26 ground water cumulative-impacts study area would be SMALL. There would be no increases in 

27 water consumption for oil recovery, agriculture, or domestic uses in the Lance and Fox Hills 

28 Formations. The drawdown from the pumping of water for EOR is expected to be greater than 

29 any of the other uses in areas where the Lance and Fox Hills aquifers supply water for oil30 production activities. The effects on ground-water quantity from uranium recovery in the Lance 

31 District would also be essentially restored within 24 years after the issuance of the NRC license 

32 to the Applicant. Cumulative impacts to ground-water quantity in the Lance and Fox Hills 

33 Formation, therefore, would be SMALL. The proposed Ross Project would have a SMALL 

34 incremental impact on the SMALL cumulative impacts to ground-water quantity in the ground 

35 water cumulative-impacts study area.

36

37 Ground-Water Quality

38

39 Impacts from previous uranium recovery at Nubeth are part of cumulative impacts to the area. 

40 Past impacts can be evaluated by comparing Nubeth’s pre-operational baseline water-quality 

41 data to Nubeth’s post-restoration data as summarized in Table 5.4 (Nuclear Dynamics, 1980; 

42 ND Resources, 1982) and to Strata’s pre-licensing baseline data as described in Section 3.5. 

43 The data in Table 5.4 show that aquifer restoration at Nubeth returned the TDS to levels below 

44 pre-licensing conditions except for the injection well No. 20X, which also contained levels of 

45 radiological parameters above pre-operational baseline values at the close of restoration. Of 

46 the seven non-injection wells in the ore zone, three were restored to pre-operational values for 

47 both gross alpha and radium-226. Uranium concentrations after restoration exceeded pre-
DRAFT Cumulative Impacts

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1 operational baseline in all of the ore-zone wells except for No. 5X. The well monitoring in the 

2 shallow-monitoring (SM) zone (No. 7X) did not show excursions of TDS and uranium. The pre3 operational baseline and post-restoration radium-226 values in No. 7X were equivalent within 

4 the analytical error of the measurement. The gross-alpha measurement of 180 pCi/L [6.7 Bq/L] 

5 in well No. 7X for 4/1980 in Table 5.4 shows excursion of radioactivity into the aquifer above the 

6 ore zone. However, gross-alpha measurements in well No. 7X during the 1979 restoration 

7 period were much lower than 180 pCi/L [6.7 Bq/L], ranging from 1.4 – 4.7 pCi/L [0.1 – 0.2 Bq/L] 

8 (Nuclear Dynamics, 1980).

9

Table 5.4

Comparison of Baseline and Post-Restoration Water Quality at Nubeth

Well in 

Zone Well Use Sample Date

TDS

(mg/L)

Gross 

Alpha

(pCi/L)

Radium226

(pCi/L)

Uranium

(mg/L)

3X in OZ Buffer Baseline 4/1978 1680 290 73 0.071

Restoration 10/1981 1500 130 22 0.24

4X in OZ Buffer Baseline 4/1978 1670 180 16 0.08

Restoration 10/1981 1510 180 26 0.22

5X in OZ Monitoring Baseline 4/1978 1600 157 0.3 0.1

Restoration 4/1980 1550 37 0.5 0.035

6X in OZ Monitoring Baseline 4/1978 1740 128 0.6 0.075

Restoration 4/1980 1650 66 0.1 0.095

7X in SM Observation Baseline 4/1978 1530 <3* 0.5 0.008

Restoration 4/1980 1400 180 0.6 <0.001

11X in OZ Monitoring Baseline 4/1978 1750 112 1.4 0.079

Restoration 4/1980 1730 116 1 0.082

12X in OZ Monitoring Baseline 4/1978 1620 72 2.3 0.073

Restoration 4/1980 1520 111 1.6 0.076

19X in OZ Recovery Baseline 4/1978 1680 310 97 0.3

Restoration 10/1981 1510 300 31 0.48

20X in OZ Injection Baseline 4/1978 1270 7.7 0.6 0.006

Restoration 10/1981 1520 85 20 0.068

10 Source: Nuclear Dynamics, 1980; ND Resources, 1982.

11 Note: 

12 * “<” = “Less than,” where the value following the “<” is the detection limit.

13

14 Evaluation of the restoration conditions in Nubeth’s wells provides a short-term assessment of 

15 past impacts. The longer-term impacts from Nubeth are determined by a comparison of 

16 Nubeth’s pre-operational baseline water-quality data with Strata’s pre-licensing baseline data as 

17 described in SEIS Section 3.5.3. The data presented in Table 3.7 in SEIS Section 3.5.3 

18 suggest that the current water quality in the ore zone and the SM zone are the same as 

19 Nubeth’s pre-operational baseline values. Thus, the aquifers are not currently impacted by past 

20 uranium-recovery activities by Nubeth. 

21

22 As described in SEIS Section 4.5.1, water quality at the Ross Project could be impacted by 

23 excursions from the ore zone into surrounding aquifers. The lixiviant injected into the ore zone 

24 causes metals such as uranium, vanadium, arsenic, selenium, and molybdenum as well as 
DRAFT Cumulative Impacts

5-27

1 other parameters such as radium to dissolve into the ground water. Despite the design of the 

2 wellfields and the pumping methods, which are to contain the uranium-recovery process within 

3 the exempted aquifer, short-term impacts from excursions do occur. As described in SEIS 

4 Sections 2.1.1 and 4.5.1, a network of monitoring wells around the perimeter of each wellfield 

5 would provide the capability for early detection, control, and reversal of such excursions; 

6 ground-water restoration would return the exempted aquifer to levels that would be established 

7 in the NRC license. As described in SEIS Section 4.5.1, therefore, the potential impacts to the 

8 ground-water quality from the Ross Project would be SMALL. 

9

10 The TDS of ground water in the Lance and Fox Hills aquifers generally increases with greater 

11 well depth and distance into the Powder River Basin (i.e. down-gradient of the Lance District) 

12 (Langford, 1964). Also, NRC license conditions would require the Applicant to recover any 

13 excursions into aquifers surrounding the ore zone. Thus, in the unlikely event that increased 

14 concentrations of metals mobilized by the lixiviant at the Ross Project migrate down-gradient, 

15 the geochemical conditions of the ore-zone aquifer outside the exempted zone would promote 

16 lower dissolved metal concentrations (i.e., would cause the dissolved metals to precipitate out). 

17 As the dissolved metals enter portions of the aquifer that had not been subjected to the 

18 oxidizing lixiviant, the naturally occurring oxygen-deficient conditions would cause chemical 

19 reactions that would precipitate the dissolved metals as minerals into the rock of the impacted 

20 aquifer. Thus, cumulative impacts to ground-water quality would be SMALL.

21

22 Thus, the incremental impacts of the proposed Ross Project in terms of both ground-water 

23 quantity and quality would be SMALL when added to the SMALL ground-water quantity and 

24 quality cumulative impacts in the ground-water cumulative-impacts study area.

25

26 5.8 Ecology

27

28 The geographic area considered in the analysis of cumulative impacts is the entire Powder 

29 River Basin (the “ecology cumulative-impacts study area”) because grassland and sagebrush 

30 shrubland habitats are important features of the Basin’s entire landscape, and these habitats 

31 occur on the Ross Project area as well. The Powder River Basin includes approximately 

32 1,801,401 ha [4,451,360 ac] of land (BLM, 2009e). Approximately 222,568 acres, or 5%, of the 

33 Powder River Basin land area has been disturbed by past development activities. Of this 

34 amount, one-half of the disturbed area has been reclaimed (BLM, 2009e). 

35

36 The timeframe for the ecological-resource cumulative-impacts analysis is from 2013 to 2032. 

37 This time frame was chosen to allow impacts to ecology of the Ross Project area and its vicinity 

38 to mature. It would take some time (the NRC has assumed five years) for the flora and fauna to 

39 fully recover after site restoration.

40

41 5.8.1 Terrestrial Ecology

42

43 Activities occurring in the vicinity of the Ross Project include livestock and wildlife grazing, 

44 agricultural production, and mineral exploration. These activities take place over a larger area 

45 of the Powder River Basin as well. As discussed in SEIS Section 4.6, potential impacts to 

46 ecological resources, both flora and fauna, include reduction in wildlife habitat and forage 

47 productivity; modification of existing vegetative communities; and potential spread of invasive 

48 species and noxious weed populations. Impacts to wildlife could involve loss, alteration, and 
DRAFT Cumulative Impacts

5-28

1 incremental habitat fragmentation; displacement of and stresses on wildlife; and direct and 

2 indirect mortalities. 

3

4 5.8.1.1 Vegetation

5

6 Vegetation at the Ross Project area is primarily sagebrush shrubland and upland grasslands, 

7 which are typical of the Powder River Basin. As discussed in Section 4.6, the impacts to 

8 vegetation at the Ross Project area would be SMALL. 

9

10 There are no operating or licensed ISR facilities within 83 km [50 mi] of the Ross Project area, 

11 although there is a potential for development of satellite areas as part of the Applicant’s 

12 development of the entire Lance District. There are also four potential ISR uranium-recovery 

13 projects in the very early stages of development as described earlier (i.e., Aladdin, Elkhorn, 

14 Hauber and Altzada). To assess the projected extent of vegetation that would be affected by 

15 the development of these prospects, the NRC staff assumed that approximately the same area 

16 affected by the Ross Project (113 ha [280 ac]) would also be affected by these other ISR 

17 projects. With this assumption, the four Lance District areas and the four other independent ISR 

18 projects would impact approximately 904 ha [2,240 ac], for a total potential vegetation impact 

19 from ISR projects in the study area of 1,017 ha [2,520 ac]. This accounts for approximately 0.05 

20 percent of the total ecology cumulative-impacts study area. Therefore, these ISR projects 

21 would have a SMALL impact on vegetation. 

22

23 Other mineral development activities described in Section 5.2, including coal-, oil-, and gas24 recovery developments, occur within the Powder River Basin. Currently, 53, 680 ha [132,645 

25 ac] of land is disturbed by these activities (BLM, 2009e). Reclamation would be required for 

26 these activities within the Powder River Basin in their respective permits. It is estimated that all 

27 but approximately 0.8 percent of the disturbed vegetation would be reclaimed (BLM, 2009e). 

28 The remaining areas would be associated with permanent infrastructure components. 

29 Therefore, the impact to vegetation within the Powder River Basin due to the identified activities 

30 would also be SMALL.

31

32 5.8.1.2 Wildlife

33

34 Loss and degradation of native sagebrush shrubland habitats has affected much of this 

35 ecosystem type as well as sagebrush-obligate species including the Greater sage-grouse. Most 

36 of the sagebrush shrublands in the Powder River Basin have already been significantly changed 

37 by land uses such as livestock grazing, agriculture, or resource extraction. These uses can 

38 influence habitats either directly or indirectly; for example, an indirect effect would be the 

39 alteration of the natural regime, which could change the frequency of land-clearing fires 

40 (Naugle, et al., 2009). For example, the long-term viability of the Greater sage-grouse 

41 continues to be at risk because of population declines related to habitat loss and degradation. 

42 Because of its spatial extent, oil- and gas-resource development is regarded as playing a major 

43 role in the decline of this species in the eastern portion of its range (Becker, et al., 2009). 

44 Therefore, there are currently MODERATE cumulative impacts to the Greater sage-grouse. As 

45 of NRC’s cumulative-impacts analysis, the USFWS has designated the Greater sage-grouse as 

46 a “candidate species” under the Endangered Species Act (ESA) and would consider the bird on 

47 an annual basis for listing as a threatened or endangered species.
DRAFT Cumulative Impacts

5-29

1 However, the impact to sagebrush shrubland communities at the proposed Ross Project would 

2 be SMALL because only 113 ha [280 ac], 16 percent of the total Project area, would be 

3 disturbed. Additionally, only 21 percent of the Ross Project area consists of sagebrush 

4 shrubland habitat. Most of the habitat disturbance would consist of scattered drilling sites for 

5 wells; these would not result in large expanses of habitat being dramatically transformed from its 

6 original character as in other surface-mining operations; no substantial long-term impact would 

7 be expected. No leks or wintering areas have been identified on the Ross Project area, and the 

8 area is not located within a designated core area for the Greater sage-grouse.

9

10 In addition, potential impacts (e.g., habitat loss, habitat fragmentation, and noise disturbance) 

11 would also likely occur at mines and oil and gas facilities throughout the geographic ecological12 resource cumulative-impacts area, and would potentially impact other localized wildlife 

13 populations. The impacts to other species would be similar; therefore, impacts from the other 

14 Lance District and other ISR projects would be SMALL. Other past, present, and reasonably 

15 foreseeable future actions discussed in the Powder River Basin could result in the disturbance 

16 of tens of thousands of acres. However, site-reclamation permit requirements and BMPs would 

17 mitigate these impacts, and it is expected that the cumulative impacts on terrestrial ecological 

18 resources would be SMALL in the Powder River Basin. Cumulative impacts to the Greater 

19 sage-grouse would continue to be MODERATE.

20

21 5.8.2 Aquatic Ecology

22

23 Three amphibians and five reptiles designated as Wyoming Species of Concern (WSOC) have 

24 been observed on the Ross Project area. However, because aquatic areas would be avoided 

25 during construction and operation, the proposed Ross Project would have a SMALL impact on 

26 aquatic resources. Similarly, due to the amount of surface disturbance in the Powder River 

27 Basin (5 percent), and the mitigation requirements associated with the regulatory permits and 

28 licenses, the cumulative impacts on aquatic ecology anticipated from the other past, present, 

29 and reasonably foreseeable future actions within the Powder River Basin would be SMALL 

30 (BLM, 2009e).

31

32 5.8.3 Protected Species

33

34 No Federal- or State-listed protected plant species or designated critical habitats occur within 

35 the proposed Ross Project area. With regard to protected species, the Ross Project has the 

36 potential to impact 12 avian species known to be present on the Ross Project area (see SEIS 

37 Section 4.6). Impacts would be SMALL, however, due to the limited footprint of the actual 

38 buildings and other structures across the entire Ross Project area. 

39

40 There are Federally listed protected species within the Powder River Basin, including the Ute 

41 ladies’-tresses orchid, the Preble’s Meadow Jumping Mouse, the Boreal Toad and the Mountain 

42 Plover (BLM, 2003). Additionally, the Bald Eagle is located throughout the Powder River Basin. 

43 On the lists of sensitive species maintained by the BLM, WGFD, and the USFS, there are 3

44 plants, 3 amphibians, 1 snake, 10 fish, 25 birds, and 8 mammals that are known to occur within 

45 the Powder River Basin. For the majority of these species, the BLM determined that there may 

46 be an affect due to development (BLM, 2003); however, considering the location of 

47 development activities compared with the occurrence of many of these species, and with the 

48 permit requirements that are in place, the impacts to all but one species would be SMALL. 
DRAFT Cumulative Impacts

5-30

1 Potential impacts to the greater sage grouse were identified by the BLM to be of particular 

2 concern.

3

4 The USFWS has designated the Greater sage grouse as a “candidate species” under the ESA, 

5 and will consider the bird on an annual basis for listing as a threatened or endangered species. 

6 Within the Power River Basin, potential impacts were identified due to loss of habitat and 

7 connectivity, construction of disposal ponds for produced waters generated during oil and gas 

8 activities, and disturbance related to increased vehicular traffic (BLM, 2003). Because of these 

9 factors, the BLM concluded that the cumulative impacts would likely result in a downward trend 

10 for the sage grouse population, and may lead to its federal listing. 

11

12 Therefore, the NRC staff determined that the cumulative impact on protected species within the

13 ecological resources study area resulting from all past, present, and reasonably foreseeable

14 future actions is SMALL to MODERATE.

15

16 Thus, the proposed Ross Project would have a SMALL incremental impact when added to the 

17 SMALL to MODERATE cumulative impacts on the ecology of the Powder River Basin.

18

19 5.9 Air Quality

20

21 The geographic area for the cumulative impacts analysis was based on the NRC staff’s 

22 consideration of other regional air-modeling studies that address larger-scale emissions sources 

23 applicable to oil and gas activities as well as a general understanding of the effect of source24 emission strength on the spatial extent and magnitude of downwind air impacts (i.e., larger 

25 plumes transport air emissions longer distances downwind before diminishing to insignificant 

26 levels). The “air-quality cumulative impacts study area” was therefore defined for air-quality 

27 emissions as a circular area formed by an 80-km [50-mi] radius around the Ross Project area. 

28 However, significant air-pollution contributors and prevention of significant deterioration (PSD) 

29 sensitive areas up to approximately160 km [100 mi] were included, as appropriate, in this 

30 analysis. As shown on Figure 5.1, an 80-km [50-mile] radius area encompasses the northeast 

31 corner of Wyoming, including the city of Gillette and numerous small towns, and extends into 

32 South Dakota and Montana. 

33

34 Any immediate air-quality impacts of the Ross Project would dissipate quickly once wellfield 

35 closure and facility decommissioning is complete and as vegetation is re-established in the 

36 areas where there was soil disturbance. The generally windy conditions present at the Ross 

37 Project readily disperse airborne pollutants and suspended particulates under the influence of 

38 gravity fall out of suspension. As described in Section 5.3.2, the timeframe considered in this 

39 assessment of air-quality cumulative impacts begins in 2013, when the NRC could issue a 

40 license for the Ross Project, and ends in 2027 when the license would be terminated at the end 

41 of the Ross Project’s decommissioning phase. After license termination, there would be no 

42 impacts on air quality by the Ross Project.

43

44 As noted in SEIS Section 4.7, the potential impacts to air quality from the Ross Project would be 

45 SMALL during each phase of the Project. Air-quality impacts primarily involve combustion46 engine emissions from both the equipment that would be used predominantly during the 

47 construction and decommissioning phases of the Ross Project as well as the combustion48 engine emissions associated with the commute of Project workers and Project deliveries and 
DRAFT Cumulative Impacts

5-31

1 shipments. In addition, there would be measurable fugitive-dust emissions from roads traveled 

2 by vehicles used for commuting, deliveries, and shipments to and from the Ross Project facility, 

3 as well as from the land-disturbing activities during, especially, the construction and 

4 decommissioning phases. 

5

6 Very small emissions are possible from processes at the CPP and/or the storage of waste 

7 liquids in the surface impoundments at the Ross Project facility. These could include minor 

8 chemical emissions during tank and vessel refilling, chemical delivery, or waste shipments. 

9 Windblown emissions from the surface impoundments are also possible. However, BMPs, 

10 SOPs, and other air-quality-related management plans, such as monitoring plans, that the 

11 Applicant would adhere to, would help mitigate air emissions and air quality impacts. Other 

12 facility-design attributes, such as exhaust-point filters, would help to reduce these potential air13 quality impacts. 

14

15 The Ross Project could contribute to air-quality cumulative impacts when its environmental 

16 impacts overlap with those of other present or reasonably foreseeable future actions. As 

17 described in SEIS Section 5.2, other past, present, and future actions in the air-quality 

18 cumulative-impacts study area could include additional ISR uranium-recovery projects, both 

19 those by the Applicant in the Lance District and four other planned ISR projects in the study 

20 area; coal, bentonite, and rare-earth element mining; oil and gas production; electricity 

21 generation by a wind farm; and the current uses of cattle and sheep grazing. However, air22 quality impacts from past operations in the study area have been resolved as demonstrated by 

23 the discussion in SEIS Section 3.7. 

24

25 Three of the most important metrics in the estimate of the cumulative impacts of combustion26 engine and fugitive-dust emissions is the amount of soil that is disturbed during a project’s 

27 construction, road installation, and wellfield drilling as well as the types of roads used to access 

28 the project (e.g., gravel roads), their maintenance, and the number of vehicles on the roads (see 

29 SEIS Section 4.7). In general, undisturbed surfaces produce much less dust than disturbed 

30 surfaces, because the undisturbed surfaces usually require considerably higher wind speeds to 

31 pick up and suspend particles that then become a significant emission source (Countess, 2001). 

32 Also in general, fugitive dusts are usually generated by ground-level activities. 

33

34 The Ross Project would ultimately disturb 113 ha [280 ac] of soil; there are, however, no other 

35 existing ISR projects within the air-quality cumulative-impacts study area that could, at the 

36 present time, generate impacts to air quality because of the disturbance of native soils. Studies 

37 have been performed to better understand the characteristics of the windblown fugitive dust and

38 mechanically re-suspended road dust that contribute to regional haze (i.e., visible air pollutants 

39 such as fugitive dust). These studies are summarized in SEIS Section 4.7.1.1 and indicate that 

40 the majority of fugitive-dust-related air-quality impacts caused by the Ross Project would not be 

41 expected to extend beyond the 80-km [50-mi] radius around the proposed Ross Project area 

42 during its entire lifecycle.

43

44 However, as described in SEIS Section 5.2, four satellite areas within the Lance District could 

45 be developed for uranium recovery by the Applicant (Strata, 2012a). The NRC staff has made 

46 the assumption that each of these satellite areas would involve the same amount of soil 

47 disturbance as the Ross Project. (This is a conservative approach, as the satellite areas would 

48 not include a CPP and surface impoundments.) Thus, the satellite areas would result in 
DRAFT Cumulative Impacts

5-32

1 approximately 450 ha [1,120 ac] of soil disturbance. It was further assumed that any air-quality 

2 impacts of these satellite areas would be mitigated with the same measures identified in SEIS 

3 Section 4.7 for the Ross Project itself. These dust-control measures would include the 

4 Applicant minimizing the area of soil that would be disturbed at any one time, spraying water to 

5 suppress dust, and promptly revegetating disturbed areas. Further, the Applicant’s enforcement 

6 of speed limits, treatment roads to minimize dust, and restriction of equipment-operation hours 

7 would further mitigate fugitive-dust impacts.

8

9 Although no other nuclear-fuel-cycle or ISR projects are currently operated within 80 km [50 mi] 

10 of the Ross Project, within the 80-km [50-mi] radius of the Ross Project area there are four 

11 other, potential uranium-recovery projects in the early planning stages as noted in Section 5.2. 

12 These include the Aladdin Project (7,100 ha [17,550 ac]), the Elkhorn Project (2,110 ha [5,215 

13 ac]), the Hauber Project (469 ha [1,160 ac]), and the Alzada Project (10,000 ha [25,000 ac]). 

14

15 It has been assumed that these projects would be developed similarly to the Ross Project and 

16 that 16 percent of the total area of each would be disturbed during these projects’ lifecycles. 

17 This would result in approximately 3,150 ha (7,840 ac) of soil disturbance. Because ISR 

18 uranium-recovery commonly employs a phased approach to well drilling and wellfield 

19 construction, and because the four facilities would not begin construction simultaneously (as 

20 each must go through an average two-year licensing process), the degree of overlap for 

21 activities associated with these four ISR projects would likely occur predominantly during the 

22 wellfield-drilling phase, not the plant construction phases. Thus, the surface disturbances likely

23 would not occur simultaneously and would not be additive. Once fugitive dust was suspended 

24 in the air, the dust would settle out within the distances described earlier (not exceeding 80 km 

25 [50 mi]. In this assessment of air-quality cumulative impacts, it has been further assumed that 

26 combustion-engine and fugitive-dust emissions as well as any processing plant emissions would 

27 be managed and mitigated in a manner similar to the Ross Project. Therefore, the relative 

28 contribution of reasonably foreseeable future ISR projects to any regional air-quality impacts 

29 would be SMALL.

30

31 As shown on Figure 5.1, 9 coal mines are located within 80 km [50 mi] of the Ross Project area, 

32 southwest of the Project (Strata, 2012a). The straight-line distances to the nine active coal 

33 mines within 80 km [50 mi] range from 45 – 72 km [28 – 45 mi]. Five surface coal mines are 

34 within approximately 48 km [30 mi] of the proposed Ross Project. This distance is sufficient to 

35 ensure that any fugitive dusts that would be generated at either the Ross Project or the coal 

36 mines would not be additive and that the particulates, whether mechanically suspended or 

37 windblown, would settle out prior to traveling those distances. 

38

39 As noted in SEIS Section 3.7.3, no violations of the ozone standard have occurred in the area. 

40 The levels reported by the nearby air-quality monitoring stations described earlier, however, are 

41 close to the respective ozone standard (see Table 3.17 in SEIS Section 4.7.1). Reasonably 

42 foreseeable future actions, if conducted concurrently with the Ross Project, could result in 

43 occasional exceedances of the ozone standard because of the cumulative number of vehicles 

44 associated with all of the activities. However, because of the distance to these mines and the 

45 pollutant mixing afforded by the winds in Wyoming, air-quality impacts related to ozone would 

46 also be SMALL.
DRAFT Cumulative Impacts

5-33

1 This conclusion is consistent with a previous evaluation by BLM of potential air-quality impacts 

2 from future coal and CBM mining, and oil and gas production in the Powder River Basin (BLM, 

3 2003; BLM, 2006; BLM, 2009b; BLM, 2009e; BLM, 2010; ENSR, 2006; BLM, 2009e). This 

4 recent BLM cumulative-impacts analysis of air quality in the Powder River Basin was conducted 

5 to support the development of increased coal production (BLM, 2009e). Emissions data were 

acquired for the base year of 2004 for NO2, SO2, PM2.5 6 , and PM10; these were then modeled to 

7 2020. The estimated impacts of the modeled emissions indicated that air-pollutant 

8 concentrations were compliant with (i.e., below) the National Ambient Air Quality Standards 

9 (NAAQS), except for the 2020 estimates where short-term and annual PM2.5 and PM10

10 standards were exceeded in localized areas. Therefore, although future coal-mine expansion 

11 and development of other projects could result in some increase in emissions in the Powder 

12 River Basin and downwind areas during the cumulative-impacts study’s general timeframe, such 

13 impacts would be SMALL. 

14

15 Ten current bentonite mining operations are within 80 km [50 mi] of the Ross Project area. The 

16 straight-line distances to the ten active bentonite mines from the Ross Project range from 5 – 88 

17 km [3 – 55 mi]. The Oshoto bentonite mine is approximately 5 km [3 mi] from the Ross Project 

18 area; the next closest bentonite mine is approximately 56 km [35 mi] distant (Strata, 2012a). 

19 Surface mining of bentonite can result in significant removal and disturbance of soils during 

20 operation, resulting in both combustion-engine and fugitive-dust emissions. However, bentonite 

21 mines must apply the same BMPs and other air-quality-management tools as would the Ross 

22 Project, including spraying exposed soils to ensure that fugitive particulates are not generated. 

23 Currently, bentonite mining has a SMALL impact on air quality. 

24

25 Finally, numerous oil fields are located within 80 km [50 mi] of the Ross Project area. In 

26 general, future development of these resources would include well installation and operation 

27 activities which would cause combustion-engine emissions and some soil disturbance,

28 generating fugitive dust. However, it has been assumed that combustion-engine and fugitive29 dust emissions would be managed and mitigated in a manner similar to the Ross Project. Both 

30 the potential rare-earth metals extraction and wind-power projects have also been assumed to

31 be required to manage and minimize each project’s respective soil disturbance and combustion 

32 emissions during construction and operation. Thus, the air-quality cumulative impacts related to 

33 these present or reasonably foreseeable future projects would be SMALL. 

34

35 Because nonradiological emissions associated with uranium recovery would be very low, as 

36 would those from existing and reasonably foreseeable future actions in the region, the NRC staff 

37 has concluded the incremental air-quality impacts of the Ross Project would be a SMALL 

38 contribution to the SMALL cumulative impacts to air quality resulting from past, present, and 

39 future actions.

40

41 5.10 Global Climate Change and Greenhouse-Gas Emissions

42

43 5.10.1 Global Climate Change

44

45 While there is general agreement in the scientific community that some change in climate is 

46 occurring, considerable uncertainty remains in the magnitude and direction of some of these 

47 changes, especially during the prediction of trends in a specific geographic location. To predict 

48 the effect on climate change of the proposed Ross Project (and vice-versa), temperature and 
DRAFT Cumulative Impacts

5-34

1 precipitation data for Wyoming were evaluated. Data have been collected over the period of 

2 1895 – 2010. On average, the temperature in Wyoming has increased approximately 0.09 °C 

3 [0.16°F] per decade during this time period (NCDC, 2011a). In its report, the U.S. Global 

4 Change Research Team (USGCRT) indicated that the temperatures in the past 15 years have 

5 risen faster (i.e., 0.83°C [1.5 °F] for the Great Plains), most of which is attributed to warmer 

6 winters (GCRP, 2009). The projected change in temperature over the period from 2000 – 2020, 

7 which encompasses the period that the Ross Project would be licensed and operated, ranges 

8 from a decrease of approximately 0.28°C [0.5 °F] to an increase of approximately 1.1 °C [2 °F] 

9 (GCRP, 2009).

10

11 For the same period (i.e., 1895 – 2010), a slight downward trend in precipitation (0.30 cm [0.12 

12 in] per decade) has been measured (NCDC, 2011b). Nevertheless, the USGCRT has predicted 

13 that the Great Plains region would receive increased precipitation in future decades. Most of 

14 the precipitation is expected to fall in the colder months (i.e., winter and spring), and the 

15 summer and fall are predicted to become drier. In addition, with the colder months expected to 

16 warm over the next several decades, more precipitation would fall in liquid form, resulting in less 

17 snow pack in the higher elevations (GCRP, 2009). 

18

19 The small predicted increases in temperatures and precipitation over the next decade would 

20 have no effect on any of the phases of the Ross Project. Because one of the most significant 

21 activities at the Ross Project would be below ground, the effects of the surficial and atmospheric 

22 environments are not expected to impact significantly uranium recovery. There could be an 

23 increase in recharge to aquifers underlying the Ross Project area in future years, which would 

24 result from the predicted increased precipitation (i.e., higher precipitation would consequently 

25 increase infiltration into the ground water regime). This could affect the Ross Project by 

26 increasing the volume of ground water in the ore-zone and improving the effectiveness of the 

27 aquifer-restoration process. Similarly, while potential changes to the Ross Project area

28 environment and its resources, such as ecology, are plausible, the small magnitude of the 

29 predicted climate change during the period when the uranium recovery would be conducted is 

30 not sufficient to alter the environmental conditions at the Ross Project area in a manner that 

31 would significantly change the environmental impacts from those that have been evaluated in 

32 this SEIS. Based on the above analysis, the proposed Ross Project’s incremental impact to 

33 predicted climate change is SMALL. 

34

35 5.10.2 Greenhouse-Gas Emissions

36

37 The evaluation of cumulative impacts of greenhouse-gas (GHG) emissions requires the use of a 

38 global-climate model. A comparison of annual carbon dioxide emissions by source is included 

39 as Table 5.5. A U.S. Global Change Research Program (GCRP) report provided a synthesis of 

40 the results of numerous climate-modeling studies (GCRP, 2009). NRC staff has concluded that 

41 the cumulative impacts of GHG emissions around the world, as presented in the GCRP report, 

42 are an appropriate basis for its evaluation of cumulative impacts. Based upon the impacts 

43 identified in the GCRP report, the national and worldwide cumulative impacts of GHG emissions 

44 are noticeable, but they are not destabilizing (refer to SEIS Section 5.3 which defines the impact 

45 magnitudes that the NRC uses). Consequently, a meaningful approach to address the 

46 cumulative impacts of GHG emissions, including carbon dioxide, is to recognize that such 

47 emissions contribute to climate change and that the carbon footprint is a relevant factor in the 

48 evaluation of potential impacts of alternatives.
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1

Table 5.5

Comparison of Annual Mass of Carbon-Dioxide Emissions by Source

Source

Annual CO2 Emissions

(tonnes [T])

Percent of World 

Emissions

Percent of U.S. 

Emissions

Global Emissions 

(EPA, 2009)

28,000,000,000 

[30,884,000,000] 100% 500%

United States

(EPA, 2009)

6,000,000,000 

[6,618,000,000] 21% 100%

Current/Proposed 

ISR Facilities

7,380 

[8,140] 0.000026% 0.00012%

Average U.S. 

Passenger Vehicles

(FHWA, 2006)

4.5

[5] Negligible Negligible

Estimated Proposed 

Ross Project 

(Strata, 2011c)

11,872

[13,087] 0.000042% 0.0002%

2 Note: t = Tonnes, or Metric tons.

3 T = Short tons, or U.S. tons.

4

5 The Center for Climate Strategies (CCS) prepared a report for the WDEQ that provides an 

6 inventory and forecast of Wyoming’s GHG emissions (CCS, 2007). These emissions data were 

7 based on projections from electricity generation, fuel use, and other GHG-emitting activities. 

8 Emissions are reported as carbon-dioxide equivalents (CO2e); this conversion renders all of the 

9 various gases emitted (i.e., methane or nitrous oxides) during an operation or activity into an 

10 equivalent GHG effect compared to carbon dioxide. Gross CO2e emissions in 2005 for 

11 Wyoming were 56 million t [62 million T]; these account for less than 1 percent (i.e., 0.8 percent) 

12 of the total U.S. gross GHG emissions. This total is reduced to 36 million t [40 million T] CO2e 

13 as a result of annual sequestration (i.e., removal) due to forestry and other land uses (CCS, 

14 2007).

15

16 Wyoming has a higher per-capita emission rate than the national average (i.e., greater than 4 

17 times the national average), due primarily to the State’s fossil-fuel-production industry, 

18 industries that consume great amounts of fossil fuels, a large agricultural industry, great 

19 distances between Wyoming cities, and a small population (EPA, 2008). The report shows that 

20 the Wyoming GHG emissions would continue to grow as demand for electricity is projected to 

21 increase, followed by emissions associated with transportation. It is estimated that Wyoming 

22 gross GHG emissions will be 69 million t [76 million T] by 2020 (EPA, 2008).

23

24 According to the Wyoming Oil and Gas Conservation Commission (WOGCC), the State of 

25 Wyoming contains over 33,000 active gas and oil wells, 45 operational gas-processing plants, 5 

26 oil refineries, and over 14,484 km [9,000 mi] of gas pipelines (CCS, 2007). Because there is no 

27 regulatory requirement to track carbon dioxide or methane emissions, there is a high degree of 

28 uncertainty associated with the estimated Wyoming GHG emissions from the oil and gas 

29 industry. However, the CCS estimated that approximately 13.5 million t [14.9 million T] of CO2e 

30 was emitted by fossil-fuel industries (CCS, 2007). Of this amount, 80 percent was due to the 

31 natural-gas industry. This amount is expected to grow an additional 8 to 10 percent in the next 
DRAFT Cumulative Impacts

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1 decade (CCS, 2007). No data currently exists for the non-fossil fuel industries, including the 

2 uranium-recovery industry.

3

4 In response to current concerns related to GHG emissions, the Applicant evaluated carbon5 dioxide emissions for the lifecycle of the Ross Project and then compared them with other forms 

6 of resource extraction. Annual and cumulative carbon-dioxide emissions from the Ross Project 

7 during the construction and decommissioning phases were estimated by the Applicant during 

8 the air-permitting process for the WDEQ (Strata, 2011c). Combustion-engine exhaust 

9 calculations performed for the Ross Project were based upon a combination of Project-specific 

10 and representative information appropriate to support a conservative emissions screening 

11 analysis. The primary source of carbon-dioxide emissions at the Ross Project would result from 

12 combustion-engine emissions from construction equipment, including drill rigs (see Table 5.6). 

13 The GHG inventory was calculated for the maximum yellowcake production rate of 1,360 t/yr 

14 [1,500 T/yr]. Construction equipment is used most frequently during initial facility construction 

15 and wellfield installation, but also later during the decommissioning phase to demolish buildings, 

16 dismantle equipment, and reclaim the land.

17

Table 5.6

Maximum Annual Greenhouse-Gas Emissions 

(CO2 in t [T])

Activity Carbon Dioxide 

(t [T])

Uranyl Tricarbonate Breakdown 640 [705]

Sodium Bicarbonate in Eluate 776 [855]

Product Drying 871 [960]

Space Heaters 1,049 [1,156]

Diesel Powered Equipment 8,433 [9,296]

Diesel Generators 104 [115]

TOTAL 11,872 [13,087]

18 Source: Strata, 2011c.

19

20 The Applicant found that minor amounts of methane and nitrous oxides, both of which are 

21 considered GHG, would be emitted during natural-gas combustion. The GHG potential or C02e 

22 of these emissions is a fraction of one percent of the carbon-dioxide emissions, and they were 

23 therefore omitted from the calculations. The maximum GHG emissions per year coincide with 

24 the year where some wellfield installation, facility and wellfield operation, and aquifer restoration 

25 would occur concurrently (i.e., Year 4).

26

27 As described above, the total gross amount of GHGs produced in Wyoming in 2005 was 56 

28 million t [61.7 million T], without the reducing effects of sequestration (EPA, 2008). If the 36 

29 million t [39.7 million T] of GHGs sequestration is taken into account (EPA, 2008), the net total 

30 of GHGs produced annually in Wyoming is 20 million t [22 million T]. The Ross Project would 

31 conservatively produce a maximum annual GHG total of 11,872 t [13,087 T] (as carbon dioxide). 

32 This figure equates to approximately 0.06 percent of the net total GHGs produced in Wyoming 
DRAFT Cumulative Impacts

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1 in 2005. If there has been an increase in GHG emissions, or a decrease in sequestration since 

2 2005, the effect of the Ross Project would be even less. 

3

4 The Applicant’s use of BMPs and other mitigation measures could minimize the emission of 

5 GHGs at the Ross Project. These mitigation measures could include, but are not limited to, the 

6 Applicant:

7

8 ■ Using fossil-fuel vehicles that meet latest emission standards.

9 ■ Ensuring that diesel-powered construction equipment and drill rigs are properly tuned and 

10 maintained.

11 ■ Using low-sulfur diesel fuel.

12 ■ Using newer, cleaner-running equipment.

13 ■ Avoiding equipment idling or equipment running unnecessarily.

14 ■ Minimizing the number of trips to drilling pads and wells.

15

16 Therefore, the potential impact of GHGs from the Ross Project would be SMALL and the 

17 cumulative impacts of GHG within the cumulative impacts study area would be SMALL.

18 5.11 Noise

19

20 Cumulative noise impacts were assessed within a rectangular area, a 300-m [1,000-ft] distance 

21 from all points of the Lance District, so as to include the potential development by the Applicant

22 of satellite areas within the Lance District (the “noise cumulative impacts study area”) (see SEIS 

23 Section 5.2). Although some noises would be detectable beyond the Lance District, this 

24 distance was considered appropriate because noise dissipates a short distance from the 

25 source. 

26

27 As described in SEIS Section 5.3.2, the timeframe considered in the assessment of potential 

28 noise cumulative impacts begins in 2013 and ends in 2027. All Ross Project-related noise of 

29 any type would cease at the end of the decommissioning phase. There would be no more 

30 activities taking place at the Project area to generate noise, nor would there be any further 

31 worker commutes to and from the Project area, supply deliveries to the area, and yellowcake 

32 shipments from the area.

33

34 As discussed in SEIS Section 4.8, the potential impacts because of noise at the Ross Project 

35 result from both activities taking place at the Project itself as well as automobiles and trucks 

36 coming and going from the Project area. The noise generated at the Ross Project area would 

37 be the greatest during its construction phase and second greatest during the decommissioning 

38 phase. Vehicular noise would be generated during all phases, however, as workers commute; 

39 as supplies, materials, and uranium-loaded resins are delivered to the Project; and as 

40 yellowcake and wastes are taken away from the Project. All of these sources of noise would 

41 generate SMALL to MODERATE impacts during the lifecycle of the Ross Project.

42

43 As shown in Figure 2.6 in SEIS Section 2.1.1, the potential development of the Lance District 

44 would occur in significantly overlapping phases. Each of the phases (i.e., construction, 
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1 operation, aquifer restoration, and decommissioning) at each of the satellite areas would 

2 produce the same noise as discussed in SEIS Section 4.8.1 for each phase of the Ross Project. 

3 At the Ross Project itself, the sources of noise are primarily associated with the operation of 

4 construction and drilling equipment during facility construction and wellfield installation as well 

5 as vehicular noise. In general, the noise generated during construction would occur during only 

6 the Ross Project’s construction, not at any of the satellite areas because the satellite areas 

7 would be predominantly only additional wellfields. However, the Applicant has indicated it 

8 expects to construct an IX facility at the Barber satellite area to treat pregnant lixiviant by IX. 

9 Thus, some construction noise can be expected there while that smaller facility is built.

10

11 As Figure 2.6 in SEIS Section 2.1.1 shows, wellfield installation would begin at the very start of 

12 the Ross Project and continue through at least 2021. During this time, other wellfields would 

13 begin to enter the aquifer-restoration phase and even decommissioning. Nonetheless, this 

14 cumulative-impacts analysis has assumed that the noise generated within the Lance District 

15 would be the same as the construction phase throughout the Project’s lifecycle, including all 

16 satellite areas. Thus, this noise—the maximum of which would occur during the CPP’s and 

17 surface impoundments’ construction during the same time the first wellfields are being 

18 installed—would be SMALL.

19

20 Based upon a construction phase where 400 passenger vehicles and 24 heavy truck trips per 

21 day would be the single highest traffic volume anticipated for the four phases of the Ross 

22 Project, the maximum estimated impacts of vehicular noise would not exceed the noise 

23 evaluated in SEIS Section 4.8, and thus these impacts would be short-term and SMALL to 

24 MODERATE (for the nearest residences). The transportation of process chemicals and 

25 supplies to the Ross Project, and yellowcake and waste shipments from the Ross Project, were 

26 predicated on the maximum yellowcake production rate of 1.4 million kg/yr [3 million lb/yr], 

27 which would include the truck delivery of uranium-loaded IX resins from the Barber satellite area 

28 to the Ross Project’s CPP. With respect to noise generated by vehicular traffic as a result of the 

29 Lance District’s development, there would be some increase in noise because of the additional 

30 uranium-loaded resins produced at the Barber satellite area being trucked to the Ross Project 

31 CPP for further treatment and production of yellowcake. As well, the anticipated maximum 

32 workforce of 60 Project-operation workers at the Ross Project was predicated on this maximum 

33 yellowcake production rate. That is, the workforce would not increase because of the additional 

34 Lance District satellite areas, were they to be developed (Strata, 2012). Thus, vehicular noise 

35 would not increase with the additional Lance District satellite areas, because the number of 

36 vehicles has already been considered in SEIS Section 4.8. 

37

38 There are no past, present, or additional reasonably foreseeable future actions within the noise 

39 cumulative-impacts study area than those in the Lance District itself; all of the ISR facilities in 

40 the preplanning stage near the Ross Project are over ten miles away from the Project area. 

41 Similarly, all other past, present, and future actions are greater than 300 m [1,000 ft] away, and 

42 no cumulative noise impacts would occur. This cumulative-impacts analysis included a search 

43 for any planned oil- and gas-extraction projects that would take place in the Lance District; 

44 however, none were identified. Because the Applicant is also unaware of any such plans, this 

45 analysis did not include any noise related to future oil- and gas-recovery wells in the Lance 

46 District. Thus, construction noise cumulative impacts would be SMALL.
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1 Some of the present and reasonably foreseeable future actions that could be constructed near 

2 the Ross Project area as described in SEIS Section 5.2, however, could produce noise 

3 cumulative impacts related to vehicular traffic. For example, the primary access route to and 

4 from the Ross Project and the Lance District would be along D Road (County Road [CR] 68) for 

5 18.3 miles, then the New Haven Road (CR 164) for 3.0 miles to the appropriate access roads 

6 onto the Ross Project area itself (see Figure 2.1 in SEIS Section 2) (Strata, 2011a). Virtually all 

7 traffic associated with the Ross Project would use this access route (Strata, 2012a). Of the 

8 present and potential projects identified during the noise cumulative-impacts analysis, the only 

9 potential projects that would share the route on D and New Haven Roads would be the Elkhorn 

10 and Hauber ISR projects. Because of the uncertainty of uranium recovery and processing 

11 methods that would be proposed, no estimate of the number of employees or truck traffic is 

12 possible at this time (Strata, 2012). However, if it is assumed that the same workforce would be 

13 required for those two developments (as was assumed in the transportation cumulative-impact 

14 analysis in SEIS Section 5.5), then there would be SMALL to MODERATE cumulative impacts 

15 with regard to noise along D and New Haven Roads. 

16

17 In addition, the existing bentonite mine just northeast of the Ross Project area would contribute 

18 to noise along some of the routes potentially taken by the Applicant’s personnel at the Ross 

19 Project. Highway-legal trucks (as opposed to heavy mine-haul trucks) transport bentonite from 

20 the Oshoto Mine to a processing and packaging plant in Upton (see Figure 5.1). The 

21 transportation route between the Oshoto Mine and Upton includes portions of D and New Haven 

22 Roads, which are adjacent to the Ross Project area and the Lance District. The bentonite truck 

23 routes also include roads north and east of the Ross Project that would not be used by Ross 

24 Project-related traffic. The degree to which the increased traffic would contribute to potential 

25 cumulative noise impacts would depend on hiring and production at Oshoto. The daily Oshoto 

26 Mine traffic is estimated at eight commuter trips and ten truck trips. This traffic was already 

27 included in the analysis of both transportation and noise impacts in SEIS Sections 4.3 and 4.8 

28 (see also Table 3.2 in SEIS Section 3.8). Thus, the noise associated with the present operation 

29 of the nearby bentonite mine has already been considered in the noise impacts found to be 

30 SMALL to MODERATE during the Ross Project’s lifecycle.

31

32 All of the sources of noise described above would be short-term and dissipate quickly with 

33 distance. For noise levels typical of drilling and construction, including multiple simultaneous 

34 noise sources in close proximity, calculations show that at the residences nearest to the Ross 

35 Project, the average noise from equipment would be significantly less than 55 dBA based on the 

36 noise data collected by the Applicant (EPA, 1978; Strata, 2011a). Given the distance between 

37 potential and existing projects, the Ross Project and Lance District areas would only contribute 

38 SMALL incremental impacts. However, given the potential noise from increased traffic on local 

39 roads as a result of present and reasonably foreseeable future projects, there would be 

40 MODERATE noise cumulative impacts to the residents living nearest the roads traversed by 

41 traffic associated with these projects. These MODERATE impacts would continue insofar as 

42 the two potential ISR projects (Elkhorn and Hauber) use the primary access roads to the Ross 

43 Project. 

44

45 5.12 Historical, Cultural, and Paleontological Resources

46

47 The assessment of cumulative impacts on historical, cultural, and paleontological resources has 

48 been geographically defined as the area of Area of Potential Effect (APE) that has been 
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1 established through the Section 106 consultation process. The APE is discussed in Section 3.9. 

2 It includes the Ross Project area, the access roads to and from the area, and a buffer outside 

3 the proposed Ross Project’s boundaries as well as the area established for potential effects to 

4 traditional cultural properties (TCPs). In relationship to other proposed undertakings with the 

5 potential to affect these resources, the regional cultural sub-area constituted by the headwaters 

6 of the Little Missouri River and the Cretaceous-era Lance Formation provide vectors for analysis 

7 of cumulative effects to the archaeological and paleontological record. 

8

9 The cumulative-impacts analysis timeframe begins in 2013, when the Applicant would be issued 

10 a license by the NRC, and concludes in 2027, the estimated year the license would be 

11 terminated after the decommissioning and site restoration of the Ross Project.

12

13 The Class I and Class III cultural resource survey conducted for the Applicant at the Ross 

14 Project area in 2010 resulted in the identification of 24 new sites and 21 isolated resources. A 

15 previously recorded site, 48CK1603, which was not found during the survey in 2010, was 

16 identified and included in an updated report provided by Strata in 2011. 15 of the sites are 

17 recommended by the Applicant as eligible for the National Register of Historic Places (NRHP). 

18 The remaining sites were determined to be ineligible for listing (Ferguson, 2010). However, the 

19 NRC staff’s evaluations to determine whether these properties are eligible for NRHP listing are 

20 ongoing. Also, sites of Tribal religious and cultural significance could potentially be identified 

21 during a TCP survey of the Ross Project area (see SEIS Section 1.7.3.2). At present, there is 

22 already some disturbance from past livestock grazing and agricultural activities as well as some 

23 encroachment due to road construction, but other effects from human activities are minimal. 

24 Erosion is currently causing some site damage as archeological and paleontological materials 

25 erode out of cut banks. In some portions of the APE where alluvium is present, some sites as 

26 yet unidentified likely remain protected by intact terraces, and they may be deeply buried.

27

28 Archaeological investigations for the Ross Project and other undertakings in the vicinity show 

29 that humans have occupied the area for at least 12,000 years (Ferguson, 2010). The Ross 

30 Project area is situated in a known culturally-sensitive area at the headwaters of the Little 

31 Missouri River, where there is potential for deeply buried archaeological materials that could 

32 provide information on earlier periods of regional culture. Ground disturbance during 

33 construction activities would be the greatest threat to archaeological sites. This includes the 

34 impacts of excavation as well as from construction of access roads. There is a risk of damaging 

35 Native American archaeological sites that may be eligible for the NRHP, depending on the 

36 depth and location of such ground disturbances. 

37

38 Ground disturbances could also have an adverse impact on TCPs by damaging landforms or 

39 other organic relationships that create or enhance a TCP’s setting. A TCP could also be 

40 damaged by compromising of the very qualities that make it significant to a community and help 

41 it to maintain and perpetuate cultural identity and values. Significant qualities could include 

42 integrity of visual setting, a sense of privacy, silence, and other factors that support the general 

43 ambiance of a natural setting.

44

45 The Project could also damage paleontological resources, as the APE is situated within the Late 

46 Cretaceous-age Lance Formation, which is known for its potential to contain a variety of fossil 

47 types. Paleontological remains in two of the prehistoric sites recorded during the Class I survey 

48 were brought to the site from elsewhere, but, as in the case of the potential for buried sites, 
DRAFT Cumulative Impacts

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1 paleontological materials of varying ages could be encountered wherever the Lance Formation 

2 is penetrated or otherwise disturbed.

3

4 To determine cumulative effects, other proposed projects in the nearby Powder River Basin 

5 were reviewed for activities that have the potential to impact historical, cultural, and 

6 paleontological resources. Other ongoing developments include activities related to energy 

7 development, including other potential ISR uranium-recovery projects, coal mines, and oil- and 

8 gas-recovery operations. The potential projects related to changing population demographics 

9 and public-service needs throughout the general vicinity include wind-power facilities; utility 

10 transmission and distribution lines; transportation infrastructure; reservoir development; 

11 agricultural activities; livestock grazing; and other economic endeavors. Activities related to all 

12 of these pursuits—in addition to natural effects, particularly erosion—have the potential to 

13 amplify the impacts of the Ross Project. These impacts taken cumulatively can lead to 

14 incremental damage to the archaeological and paleontological record by the elimination of 

15 potential data points from the cumulative record of the entire vicinity.

16

17 The Applicant expects to develop subsequent areas of the Lance District for uranium-recovery 

18 satellite operations (see Figure 2.2 in SEIS Section 2.1.1). No information on identified cultural 

19 resources is available for the Lance District; however, similarity in landscape and existing 

20 conditions make it likely that the impacts to historical, cultural, and paleontological resources 

21 would be similar to those resulting from Ross Project.

22

23 Cumulative-impacts analysis for the Moore Ranch project, which is the nearest operating ISR 

24 facility to the Ross Project, indicated that the potential impacts of its construction and operation 

25 would be small, because the Moore Ranch project is not expected to directly impact eligible 

26 archaeological sites when added to the moderate cumulative impacts to the resources from 

27 other past, present, and reasonably foreseeable future actions (NRC, 2010). The Nichols 

28 Ranch ISR facility, approximately the same distance from the Ross Project area as the Moore 

29 Ranch project, identified numerous “pre-contact” sites (i.e., the period of time prior to the arrival 

30 of Euroamericans) and deemed the impacts from that project to be small to moderate, and 

31 cumulative effects to be moderate. 

32

33 The BLM has identified proposed coal-mining operations in the Powder Basin as well as 

34 continuing development trends. Impacts arising from development of mines, access roads, and 

35 related transportation infrastructure, such as extensions of railways, could have a varying effect 

36 on historical, cultural, and paleontological resources, depending on where they are sited, but 

37 such development is projected to increase at least over the next few years in the Powder River 

38 Basin. The same is true of quarries for sand, gravel, and scoria, all of which are used in road 

39 construction and maintenance.

40

41 CBM and oil and gas exploration and delivery are also expected to continue increasing with 

42 population growth and its attendant energy demands. These increases, however, are tempered 

43 by economic and regulatory factors. Development of these projects would also be similar to 

44 uranium-recovery projects, potentially involving the construction of access roads, pipelines, 

45 utility transmission lines, and support facilities of various types as well as ground-water-well 

46 installation and facility decommissioning activities.
DRAFT Cumulative Impacts

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1 Mitigation measures can reduce or minimize some impacts to historical, cultural, and 

2 paleontological resources. Sites could be deliberately avoided during construction, by flagging 

3 them or protecting them with a barrier. Careful monitoring during construction and the 

4 implementation of an inadvertent discovery plan can also provide a measure of avoidance or 

5 minimize impacts to sites as well as to paleontological discoveries. When impacts are 

6 unavoidable, data recovery is often proposed as mitigation measure. A Memorandum of 

7 Agreement (MOA) between the NRC, BLM, Wyoming State Historic Preservation Office 

8 (SHPO), the Applicant, and the respective Tribes would stipulate the management and 

9 treatment of discovered sites and would support ongoing consultation with the Tribes designed 

10 to avoid adverse impacts to archaeological sites, TCPs, and other cultural resources. Activities 

11 which are on Federally-managed lands or are subject to Federal licenses and permits would be 

12 expected to generate fewer impacts, as each is required to undertake the consultation process 

13 stipulated in Section 106 of the NHPA. Impacts can be greater on lands, including private or 

14 even State, that are not Federally administered. These would include impacts to physical 

15 remains as well as the integrity of their settings. 

16

17 The National Historic Preservation Act (NHPA) provides regulatory thresholds for the 

18 assessment of impacts to historic properties, which would include the identification of the loss of 

19 characteristics that make the properties eligible for the NRHP as well as loss of integrity. For 

20 archaeological sites, these impacts could entail an incremental loss of data. For TCPs, these 

21 impacts could entail a gradual decline of the very qualities that make a property a functioning 

22 element, important for its role in maintaining a living culture. 

23

24 While data recovery is a mitigation option that is often included in a treatment plan, 

25 archaeological sites are nonrenewable resources, and loss of any data contributes to the net 

26 loss of information on local and regional cultural history. Whether sites are removed by 

27 inadvertent destruction or intended data collection, this loss of these properties precludes any 

28 additional investigation in the future, when advances in the field could change interpretations or 

29 allow new methodologies to be applied. Paleontological resources are also non-renewable, and 

30 they are subject to the same cumulative risks.

31

32 Due to urbanization, population growth, and its attendant development, Tribal peoples are 

33 experiencing an ongoing loss of TCPs, places that play a vital role in maintaining and 

34 perpetuating cultural identity and values. Along with other threats to their life ways, the loss of 

35 any culturally empowering resource has a cumulative impact on a group’s ability to maintain its 

36 cultural identity.

37

38 The NRC staff has concluded that the cumulative impacts on historical, cultural, and 

39 paleontological resources in the study area resulting from past, present, and reasonably 

40 foreseeable future actions is MODERATE to LARGE. The Ross Project would have a SMALL 

41 to LARGE incremental effect on historical, cultural, and paleontological resources when added 

42 to the MODERATE to LARGE cumulative impacts of the facilities and operations described 

43 above. However, the NRC staff’s Section 106 consultation for the Ross Project is ongoing as 

44 are efforts to identify properties, determine effects, and develop mitigation measures to reduce 

45 impacts. The Ross Project is located within an archaeologically rich area; the activities 

46 described above could result in a cumulative loss of historical, cultural, and paleontological 

47 resources. The impacts to TCPs cannot be determined at this time as TCP identification is still 

48 ongoing, as described in Section 1.7.3.2 and Section 4.9. However, any past, present, and 
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1 reasonably foreseeable future actions that occur on Federal land or require a Federal license or 

2 permit would require Section 106 consultations, which would be expected to ensure that 

3 historical, cultural, and paleontological resources are adequately protected.

4

5 5.13 Visual and Scenic Resources

6

7 The geographic area used in this analysis of visual and scenic cumulative impacts (the “visual8 resources cumulative-impacts study area”) is a circular area with a 32-km [20-mi] radius around 

9 the Ross Project area. This area was established as the geographic boundary because it 

10 includes the recreational destinations in the immediate vicinity of the Ross Project (described in 

11 SEIS Section 3.10), and it addresses the highest (i.e., most sensitive) visual-classification areas 

12 in the vicinity of the Ross Project as well. Devils Tower, Thunder Basin National Grassland, 

13 Keyhole Reservoir State Park, and the Black Hills National Forest all fall within this visual14 resources cumulative-impacts study area. As discussed in SEIS Section 5.3.2, the time frame 

15 evaluated for the cumulative-impacts analysis is 14 years, to the year 2027.

16

17 As described in SEIS Section 4.10, the potential impacts on visual and scenic resources from 

18 the Ross Project include the contrast of surface infrastructure (e.g., drilling rigs, the CPP, 

19 access roads, and utility lines) with the existing visual inventory. These types of visual impacts 

20 are consistent with the management objectives of the VRM Class IV area in which the Ross 

21 Project area is located. Thus, the potential impacts to visual and scenic resources from the 

22 surface structures and equipment of the Ross Project would be SMALL during all phases, 

23 except during construction phase. The short-term impacts to visual and scenic resources from 

24 construction activities would be MODERATE. 

25

26 Many of the construction and operation activities (e.g., drilling, pipeline and wellfield installation, 

27 and surface infrastructure assembly, such as access-road, utility-corridor, and lighting-system 

28 construction) at the present and reasonably foreseeable future projects identified in SEIS 

29 Section 5.2, both uranium recovery as well as oil production, are very similar to those described 

30 in SEIS Section 4.10. In addition, the bentonite mine has already become a fixture of the 

31 landscape in the cumulative-impacts area. There are no coal mines within the 32-km [20-mi] 

32 radius of the visual and scenic resources cumulative-impacts area. Thus, the same types of 

33 impacts to visual and scenic resources described in SEIS Section 4.10 would be associated 

34 with these other mineral-extraction and energy-production activities that occur or could occur 

35 within the 32-km [20-mi] radius of the Ross Project.

36

37 All of these developments, however, would take place in the existing classifications of VRM 

38 Class III or IV, where change to an environment can be moderate or even undergo significant 

39 modification. In addition, many of the mitigation measures that would be used to reduce the 

40 contrast of the Ross Project structures with the existing visual inventory would also be required 

41 of new areas and projects. The lower profile and smaller footprint associated with the Ross 

42 Project, and presumably with the other satellite areas and planned ISR projects, would diminish 

43 visual impacts as well. 

44

45 Thus, the NRC staff concluded that the cumulative impacts to the viewshed within the 32.2 km 

46 [20 mi] visual-resources cumulative-impacts study area as a result past, present, and 

47 reasonably foreseeable future actions would be MODERATE. The Ross Project would 

48 contribute a SMALL incremental impact and a MODERATE short-term incremental impact to the 
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1 MODERATE potential cumulative impacts to the viewshed within the 32.2 km [20 mi] visual2 resources cumulative-impacts study area. 

3 5.14 Socioeconomics

4

5 The geographic scope for this cumulative socioeconomics analysis are the six counties of 

6 Crook, Campbell, Weston, Sheridan, Johnson, and Converse, consistent with the geographic 

7 scope of the BLM’s Report for the Powder River Basin Coal Review Cumulative Social and 

8 Economic Effects (BLM, 2005b), the “socioeconomics cumulative-impacts study area” for coal9 related impacts. The timeframe for this analysis is 2013 through 2027.

10

11 The potential socioeconomic impacts of the Ross Project range from SMALL to MODERATE, 

12 with the MODERATE impacts associated with the benefits of the additional tax revenue 

13 projected to accrue to Crook County. Because the size and scope of the Ross Project relative 

14 to existing employment levels in a two-county ROI are small (see SEIS Section 4.11), and the 

15 Applicant is committed to hiring locally, the population impacts and the associated increase in 

16 demand for public and private services are expected to be SMALL. 

17

18 There have been, however, a number of energy-related developments recently completed in the 

19 region as well as the proposed projects in the ROI that have the potential to cause additional 

20 impacts to socioeconomics areas of study. The projects considered in the BLM report cited 

21 above include two additional coal mines over the 2003 – 2010 period; 9,519 additional 

22 conventional oil and gas wells, with over one-half of these in place over the 2003 to 2010 

23 period; 62,868 additional CBM wells, with about 40 percent of these in place over the 2003 –

24 2010 period; and 3 – 4 new coal-fired power plants, with three in place over the 2003 – 2010 

25 period and 1 additional plant planned in the 2016 to 2020 period.

26

27 Socioeconomic impacts have been projected over both a low-production scenario and a high28 production scenario. Under the low production scenario, the 2020 population in the six-county 

29 area is projected to increase by 24,100 persons over 2003 levels, reflecting an increase of 25.1 

30 percent, with 55.8 percent of the increase attributed to projects already in place by 2010 (BLM, 

31 2005b). Under the high-production scenario, the 2020 population in the six-county area is 

32 projected to increase by 28,625 persons over 2003 levels, reflecting an increase of 29.8 

33 percent, with 54.0 percent of the increase attributed to projects already in place by 2010. Under 

34 both scenarios the large majority (over 70 percent) of the increase is projected in Campbell 

35 County, the regional commercial and services center for the region.

36

37 The population increases through 2010 already have shown up in the U.S. Census Bureau data 

38 for 2010. Population over the 2000 – 2010 period in Campbell County increased 36.9 percent 

39 and increased 20.3 percent in Crook County (see Section 3.11). In contrast, population growth 

40 in Wyoming was 14.1 percent per year over the same period.

41

42 Population increases associated with other current and proposed ISR projects in the ROI would 

43 be in addition to those discussed above. Some of the additional potential projects would involve 

44 only wellfield construction at satellite areas, including those associated with the Applicant’s 

45 development of satellite areas in the Lance District. However, in this cumulative-impacts 

46 analysis, the NRC staff has assumed that the other planned ISR projects in the 80-km [50-mi] 

47 vicinity have the same construction and operating characteristics as the Ross Project, meaning 
DRAFT Cumulative Impacts

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1 that, at peak construction employment, including the employment associated with the Ross 

2 Project, all ISR projects within 80 km [50 mi] would create approximately 2,080 jobs. If these 

3 additional projects are online and operating through 2027, operation-phase employment levels 

4 would total approximately 540 jobs. If these other ISR projects follow the Applicant’s local hiring 

5 and purchasing patterns, peak construction population increases would amount to an additional 

6 436 residents in the two-county ROI while the operation-phase population increases by 2027 

7 would total an additional 248 residents. The additional operation-phase population would 

8 increase the projected six-county population in 2027 to 24,348 residents, or a 25.4 percent 

9 increase over 2003 levels under the low-production scenario, and to 28,873 residents under the 

10 high-production scenario, or a 30.1 percent increase over 2003 levels.

11

12 Campbell County and local jurisdictions throughout the Powder River Basin have shown their 

13 ability to respond these periods of rapid growth. As an example, in response to Campbell 

14 County population increases of 36.9 percent over the 2000 – 2010 period, new housing 

15 construction increased 42.5 percent over the same period (USCB, 2002; USCB, 2012). 

16 Similarly, new housing construction in Crook County increased 22.5 percent compared to 

17 population growth of 20.3 percent over the same period.

18

19 Periods of rapid growth can stress other public and private service delivery systems. Over the 

20 2010 – 2027 period, population in the six-county area, including the additional residents 

21 associated with operation-phase activities of the additional planned ISR projects, is projected to 

22 increase by another 10,900 persons, a 10.0 percent increase, under the low-production 

23 scenario, and another 13,419 persons, a 12.2 percent increase, under the high-production 

24 scenario. Under the low-production scenario, BLM (2005b) also projects enrollment in 

25 Campbell County School District No. 1 to increase by 1,587 additional students by 2020, 

26 reflecting a 22 percent increase over recent levels; this could cause short-term capacity 

27 shortfall. Under the high-production scenario, enrollments could increase another 10 percent. 

28 Water and waste-water systems in all communities in the six-county area would have the 

29 capacity to accommodate the projected increases in demand through 2020. However, if 

30 ongoing and planned improvements are completed (BLM, 2005b), short-term peak demands 

31 might result in the need for temporary rationing. This would be a MODERTAE impact. 

32

33 While local county jurisdictions are expected to benefit from the increased tax revenues from 

34 these various projects, some directly from increased property taxes and others indirectly from 

35 worker spending and local purchases of goods and services from project proponents, this 

36 benefit would be offset by additional demands for public services. Additional street and highway 

37 improvements would likely be required in response to the increasing population as well (see 

38 SEIS Section 5.5) (BLM, 2009a). Increased traffic levels would also result in increased demand 

39 for law-enforcement services and emergency-response services, and similar increases in the 

40 demand for health services are expected. 

41

42 Although the incremental socioeconomic impacts of the Ross Project are SMALL with 

43 MODERATE impacts to finance, as the cumulative population increases and their consequent 

44 impact on the demand for other public and private community services rises as well, there would 

45 be MODERATE socioeconomic cumulative impacts.
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1 5.15 Environmental Justice

2

3 Because no minority or low-income populations, as defined by Executive Order 12898 have 

4 been identified in the Ross Project area, no disproportionate human-health and environmental 

5 impacts were determined. Therefore, there are no cumulative impacts expected in minority and 

6 low income populations near the Ross Project.

7

8 5.16 Public and Occupational Health and Safety

9

10 Cumulative impacts to public and occupational health and safety were assessed along the 

11 roads of the circular area defined by an 80-km [50-mi] radius around the Ross Project area (the 

12 “public and occupational health and safety cumulative-impacts study area”). This area includes 

13 the potential development of satellite areas within the Lance District by the Applicant, four other 

14 potential ISR projects, and the other past, present, and other reasonably foreseeable future 

15 projects described in SEIS Section 5.2. As described in SEIS Section 5.3, the timeframe for this 

16 cumulative-impacts analysis is 2013 to 2027, the expected lifecycle of the Ross Project, 

17 including potential uranium-recovery activities in the Lance District. There would be no potential 

18 impacts on public or occupational health and safety from the Ross Project following its license 

19 termination. 

20

21 The public and occupational health and safety impacts from the proposed Ross Project would

22 be SMALL and are discussed in Section 4.13. During normal activities associated with all 

23 phases of the project lifecycle, radiological and nonradiological worker and public health and 

24 safety impacts would be SMALL. Annual radiological doses to the population within 80 km [50 

25 mi] of the proposed project would be far below applicable NRC regulations. For accidents, 

26 radiological and nonradiological impacts to workers could be MODERATE if the appropriate 

27 mitigation measures and other procedures to ensure worker safety are not followed. Typical 

28 protection measures, such as radiation and occupational monitoring, respiratory protection, 

29 standard operating procedures for spill response and cleanup, and worker training in 

30 radiological health and emergency response, would be required as part of the Applicant’s NRC31 approved Radiation Protection Program (RPP) (Strata, 2011a). These procedures and plans 

32 would reduce the overall radiological and nonradiological impacts to workers from accidents to 

33 SMALL. 

34

35 As shown in Figure 5.1 and discussed in SEIS Section 5.2, in addition to the Ross Project, four 

36 satellite areas could be developed by the Applicant and four other ISR projects could be brought 

37 to construction and operation during the timeframe of this cumulative-impacts analysis. If 

38 constructed and operated, all of these facilities would have similar radiological and 

39 nonradiological impacts on the public and occupational health and safety to those at the Ross 

40 Project site. Potential radiological cumulative impacts from these facilities would result from 

41 incremental increases in annual radiological doses to the population when combined with the 

42 impacts of the proposed Ross Project. As stated in Section 4.13, for normal operations, Rn-222 

43 and its progeny would be the most prevalent radionuclides, by dose contribution, anticipated to 

44 be released during normal operations at the proposed Ross Project. As further described in 

45 SEIS Section 4.13, the maximum expected exposure to a member of the public is estimated to 

46 be 0.008 mSv/yr [0.799 mrem/yr] and is consistent with estimates of exposure levels at other 

47 operating ISR facilities in the United States (NRC, 2009). This exposure, combined with 

48 exposures from other potential ISR facilities in the study area, would remain far below the 10 
DRAFT Cumulative Impacts

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1 CFR Part 20 public dose limit of 1.0 mSv/yr [100 mrem/yr] and have a negligible contribution to 

2 the 6.2 mSv [620 mrem] average yearly dose received by a member of the public from all 

3 sources.

4

5 As described in SEIS section 4.13, both worker and public radiological exposures are 

6 addressed in NRC regulations at 10 CFR Part 20. Licensees are required to implement an 

7 NRC-approved RPP to protect workers and ensure that radiological doses are “as low as 

8 reasonably achievable” (ALARA). The Applicant’s RPP includes commitments for implementing 

9 management controls, engineering controls, radiation safety training, radon monitoring and 

10 sampling, and audit programs (Strata, 2011a). Measured and calculated doses for workers and 

11 the public are often only a fraction of regulatory limits. Analyses of various radiological accident 

12 scenarios, described in section 4.13, also estimate that the dose to the public would be a 

13 fraction of the applicable regulatory limits. 

14

15 Other developments in the 80-km [50-mi] area include existing and potential coal, oil, gas, and 

16 bentonite projects. The concomitant major nonradiological occupational hazards of all of these 

17 existing or future facilities would be similar to those at the Ross Project; that is, they would 

18 include slips, trips, and falls, which could then result in musculoskeletal injuries; potential 

19 exposures to excessive noise; potential inhalation of particulates, gasses, or vapors; and skin 

20 contact with corrosive materials. These impacts would only be present at the actual facilities 

21 where occupational risks are located; the distance between the facilities and operations in the 

22 public and occupational health and safety cumulative-impacts analysis study area suggests that, 

23 if an occupational hazard were to be experienced, such as a chemical release into the air, the 

24 distance itself would mitigate the resulting impacts and would limit impacts to the onsite 

25 workers. 

26

27 All of the facilities and operations identified above would be required to implement the same or 

28 similar mitigation measures as at the Ross Project. For example, all such facilities would be 

29 required to have spill-response plans, Occupational Safety and Health Administration (OSHA)-

30 compliant SOPs, and health and safety plans as a matter of course because all such facilities 

31 are subject to State and Federal occupational health and safety requirements. Thus, 

32 nonradiological cumulative impacts to occupational workers would be SMALL, since there would 

33 be no cumulative-effects between facilities or projects. However, in the unlikely event that an 

34 accident or spill is not mitigated, the impacts to workers could be MODERATE.

35

36 The cumulative impacts to the public from nonradiological normal operations would be SMALL, 

37 because the public would not have access to the facilities included in this cumulative-impacts 

38 analysis. Concurrent generation of fugitive dusts at various operations could occur, if they were 

39 closely located to each other, but these facilities would implement the same or similar BMPs for 

40 fugitive-dust and combustion-emissions control as described in SEIS Section 4.7. (See also 

41 SEIS Section 5.9 regarding air-quality cumulative impacts.) The very distance from the Ross 

42 Project to the other potential ISR, coal, gas, oil, and bentonite facilities preclude fugitive-dust 

43 cumulative impacts due to not only similar BMPs, SOPs, and other mitigation measures, but 

44 also due the significant winds in the study area which would disperse the fugitive dust rapidly.

45

46 Potential accidents and chemical releases could affect the public, depending upon the location 

47 of the release and the nearest receptors, the closest of which is 0.21 km [690 ft] from the Ross 

48 Project’s boundary. Accidents could include bulk chemical spills during transport, during 
DRAFT Cumulative Impacts

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1 operations or maintenance, or during product or waste shipment. Spill prevention and response 

2 mitigation measures would include training of all personnel as well as standard spill-response 

3 plans. Coordination between both present and future ISR projects, especially the two that 

4 would use the same county roads as are adjacent to the Ross Project area (the Hauber and 

5 Elkhorn uranium-recovery projects), could optimize emergency-response activities and efficient 

6 response. Thus public impacts could range from SMALL to MODERATE, if accidents are not 

7 appropriately managed. 

8

9 Because Strata will implement preventative and mitigation measures, the incremental impacts 

10 on public and occupational health and safety of the proposed Ross Project would be SMALL 

11 when added to the SMALL cumulative impacts of other past, present, and reasonably 

12 foreseeable future actions.

13

14 5.17 Waste Management

15

16 The cumulative impacts of waste management at the Ross Site were evaluated for both liquid 

17 and solid waste streams.

18

19 5.17.1 Liquid Wastes

20

21 There are two types of potential liquid waste disposal techniques that would be used at the 

22 Ross Project: those that employ deep-well injection and those that do not.

23

24 The Applicant estimates the completion of Ross Project’s (i.e., CPP’s) decommissioning and 

25 that of the Lance District satellite areas to be approximately 14 years after the NRC license 

26 would be issued. Since the impacts from deep-well injection would take some time to dissipate, 

27 20 years is used as the timeframe for evaluation of these cumulative impacts (i.e., the year 

28 2032). Except for the domestic sewage and the used oil, which would be managed only for the 

29 lifecycle of the Lance District satellite areas, the generation of other liquid wastes, such as 

30 excess permeate as well as fluids and ground water from monitoring wells, would cease during 

31 Ross Project operation and aquifer restoration, respectively. 

32

33 5.17.1.1 Disposal by Deep-Well Injection

34

35 The geographic area selected for cumulative-impacts analysis for the management of liquid 

36 wastes into the UIC Class I deep-injection wells is similar to the area defined as the ground37 water cumulative-impacts study area in SEIS Section 5.7. This area extends westward into the 

38 Powder River Basin, to the stratigraphic dip approximately 60 km [37 mi] west of the Ross 

39 Project, where the Cambrian aquifers targeted for waste injection at the Ross Project are over 

40 3,700 m [12,000 ft] below the ground surface at that location. This depth to the aquifers make 

41 drilling Class I wells impractical; thus, the aquifers accessed at the Ross Project would not be 

42 penetrable at that western location. Also, at this location within the Basin, injection wells make 

43 use of the Upper Cretaceous aquifers at depths of 1,200 – 2,900 m [4,000 – 9,500 ft]. The 

44 aquifers in the Upper Cretaceous are: Tecla, Teapot, and Parkman members of the sandy 

45 intervals of the Pierre Shale; Lance and Fox Hills Formations; and the Tullock member of the 

46 Fort Union Formation above the Lance Formation. These aquifers are used for UIC Class I and 

47 Class V injection wells at existing uranium-recovery operations in Campbell, Johnson, and 

48 Converse Counties (NRC, 2010; NRC, 2011; WDEQ/WQD, 1999; WDEQ/WQD, 2010).
DRAFT Cumulative Impacts

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1 The other boundaries of the “waste-management cumulative-impacts study area” for deep-well 

2 injection would be the 80-m [50-mi] radius shown in Figure 5.1. This area includes the three 

3 ISR projects that may be located in Crook County (in addition to the Ross Project and the four 

4 Lance District satellite areas potentially operated by the Applicant) and another one just over the 

5 state line, in Montana. These potential projects were described earlier, in SEIS Section 5.2.

6

7 As described in SEIS Section 2.1.1.1, the liquid wastes generated by the Ross Project would 

8 include byproduct wastes, predominantly brine from the RO process and other process waters. 

9 These wastes would be stored in lined surface impoundments and then disposed of into the UIC 

10 Class I deep-injection wells, into the Deadwood and Flathead Formations (WDEQ/WQD, 2011). 

11 As noted earlier in SEIS Section 4.14, impacts of the management and disposal of liquid 

12 byproduct wastes into the UIC-permitted deep-injection wells at the Ross Project would be 

13 mitigated by the Applicant’s adherence to permit requirements and would be SMALL.

14

15 5.17.1.2 Disposal by Other Methods

16

17 The geographic area for cumulative impacts from soil disturbances, such as the mud pits at the 

18 drilling pads and the lined surface impoundments, is the circular area with an 80-km- [50-mi]-

19 radius around the Ross Project area as shown in Figure 5.1.

20

21 Liquid non-byproduct wastes would include drilling fluids and muds from the installation of 

22 injection, recovery, and monitoring wells; small amounts of used oil; and domestic sewage. 

23 BMPs, management plans, and WDEQ permit requirements would be implemented to mitigate 

24 such waste-management and disposal techniques. For drilling fluids and muds, the respective 

25 management technique would be their evaporation and disposal in mud pits near each drillhole, 

26 and the pits would subsequently be reclaimed when the Ross Project area is restored to pre27 licensing, baseline conditions. All used oils would be taken offsite to a properly permitted oil 

28 recycler. Finally, the domestic-sewage system installed onsite would follow the required 

29 standards and practices as well as all permitting requirements. Thus, as described in SEIS 

30 Section 4.14, the impacts of the management and disposal of liquid non-byproduct wastes at 

31 the Ross Project would also be SMALL. 

32

33 Four potential uranium-recovery projects outside of the Lance District, but within 80 km [50 mi] 

34 of the Ross Project have been identified. These projects are located east and northeast of the 

35 Ross Project and would recover uranium from the lower Cretaceous Fall River and Lakota 

36 sandstones. They range from 11 – 70 km [7 – 44 mi] from the Ross Project. Uranium 

37 production at each of these potential ISR uranium-recovery projects is expected to be less than 

38 the Ross Project (Strata, 2012a). The area encompassing the Ross Project and future potential 

39 projects is approximately 0.5 million ha [1.3 million ac].

40

41 The use of UIC Class I deep-injection wells for the disposal of liquid byproduct wastes would be 

42 expected at these projects, if these projects were to become licensed. It appears likely, given 

43 the stratigraphy, that the same aquifers targeted by the deep-injection wells at the Ross Project 

44 would be used for disposal at these future projects. For example, the Dewey-Burdock uranium45 recovery project in the eastern portion of the NSDWUMR, is stratigraphically similar to the future 

46 projects near the Ross Project. The Dewey-Burdock project, located in the Edgemont uranium 

47 district in South Dakota, would recover uranium from the Fall River and Lakota sandstones and 
DRAFT Cumulative Impacts

5-50

1 has proposed deep-injection wells in the Minnelusa and Deadwood Formations, the same that 

2 would be used for the Ross Project (NRC, 2009; Powertech, 2010). 

3

4 The U.S. Environmental Protection Agency (EPA) has determined that the area of potential 

5 impacts from deep-well injection is generally less than 0.4 km [0.25 mi] (EPA, 2001). Thus, 

6 EPA has defined an “area of review” as the zone of endangering influence around the well, or 

7 the radius at which pressure due to injection may cause the migration of the injected wastes 

8 and/or poor-quality water in the target formation into an underground drinking water source. 

9

10 In addition, earthquakes induced by underground waste disposal have been rare, because 

11 typically large, porous aquifers are targeted and injection pressures are sufficiently low so that 

12 seismic activity is avoided (Nicholson and Wesson, 1990). Nicholson and Wesson documented 

13 only two instances in which waste disposal triggered significant adjacent seismicity. If 

14 earthquakes were to be induced by fluid-injection activities, they would be located within a few 

15 miles from the point of injection.

16

17 The WDEQ/WQD’s UIC Class I Permit prescribes well design, injection rates, permitted wastes, 

18 and injection pressures. Careful monitoring is required to characterize post-licensing, pre19 operational baseline water quality of the targeted aquifer and pressures of the lowermost 

20 drinking-water aquifer for a new well. Operational monitoring is required to record continuously 

21 the rate, volume, and pressure of injection. Every two years, wells must be tested to determine 

22 the radius of influence and to compare the results with historical and expected future responses. 

23 These required data would provide the information necessary for an assessment of cumulative 

24 impacts.

25

26 During this analysis, the NRC assumed that all five UIC Class I wells that are already permitted 

27 for the Ross Project would be installed and that an average of three UIC Class I wells would be 

28 installed at each of the four potential future projects near the Ross Project; thus, there would be 

29 17 deep-injection wells within the approximately 0.5 million-ha [1.3 million-ac] area. The overall 

30 density of injection wells would consequently be very low. Given that the potential impacts from 

31 deep-well injection are localized, generally 0.4 km [0.25 mi], the cumulative impacts of disposal 

32 of liquid byproduct wastes would be SMALL, to which the Ross Project would contribute only a 

33 SMALL incremental impact.

34

35 5.17.2 Solid Wastes

36

37 The geographic area selected for solid waste-management cumulative-impacts analysis is the 

38 Ross Project area itself and, though disconnected, the areas that would be impacted by the 

39 actual disposal of each type of solid-phase waste that would be generated at the Ross Project 

40 (the “solid-waste-management cumulative-impacts study area). Because most of the waste41 disposal facilities that would accept the Ross Project’s wastes would be open through 2027, the 

42 NRC’s waste-management cumulative-impacts analysis assumed that the cumulative impacts of 

43 waste management would occur through 2027. 

44

45 The waste-management impacts of the Ross Project were determined to be SMALL in SEIS 

46 Section 4.14 through all of the Project phases. This impacts magnitude is primarily a result of 

47 the relatively small solid-waste volumes that would be generated at the Ross Project. Even 

48 during the decommissioning of the Ross Project, the volumes of the different types of solid 
DRAFT Cumulative Impacts

5-51

1 wastes, including radioactive waste, would be relatively small due to the decontamination efforts 

2 anticipated by the Applicant as well as the fact that the Ross Project would not generate 

3 substantial quantities of waste when dismantled and/or demolished (uncontaminated equipment 

4 would be re-used).

5

6 For the waste-management cumulative-impacts analysis, the NRC assumed that all of the 

7 waste-disposal facilities that would accept and dispose of Ross Project wastes would have been 

8 properly licensed or permitted. (And that all Ross Project waste shipments would be managed 

9 as required in the pre-operational agreements the Applicant must set up with the respective 

10 waste-disposal facilities prior to uranium-recovery.) Every waste-disposal facility must undergo 

11 significant pre-operational planning and design. This is especially true for the radioactive-waste 

12 disposal facilities which could accept the Ross Project’s radioactive waste. These facilities 

13 would have been licensed by the NRC or by an Agreement State; the other, non-radioactive 

14 facilities would have been permitted on the county- or State-level. Also, licensed or permitted 

15 facilities that generate solid byproduct material would be required to demonstrate that they have 

16 a valid agreement with a solid byproduct material disposal facility in order to continue to 

17 operate. This requirement would help to ensure that the byproduct disposal facilities have 

18 sufficient capacity to accept incoming material. 

19

20 Consequently, the incremental impact of the Ross Project’s waste management would be 

21 SMALL when considered with the SMALL cumulative impacts of waste management over the 

22 solid waste management cumulative-impacts study area.

23

24 5.18 References

25

26 40 CFR Part 1500 to 40 CFR Part 1508. Title 40, “Protection of the Environment,” Code of 

27 Federal Regulations, Part 1500, “Purpose Policy and Mandate,” through Part 1508, 

28 “Terminology and Index.” Washington, DC: Government Printing Office. 1978, as amended.

29

30 Becker, J.M., C.A. Duberstein, J.D. Tagestad, and J.L. Downs. “Sage-Grouse and Wind Energy: 

31 Biology, Habits, and Potential Effects of Developmen.t” Prepared for the U.S. Department of 

32 Energy, Office of Energy Efficiency and Renewable Energy, Wind and Hydropower 

33 Technologies Program. Contract DE–AC05–76RL018302009. At http://www.pnl.gov/main/ 

34 publications/external/technical_reports/pnnl-18567.pdf (as of December 8, 2012). . 

35 Agencywide Documents Access and Management System (ADAMS) Accession No. 

36 ML13011A248. 

37

38 BLM (U.S. Bureau of Land Management). Final Environmental Impact Statement and Proposed 

39 Plan Amendment for the Powder River Basin Oil and Gas Project. Volumes 1 – 4. WY-072-02-

40 065. Buffalo, WY: USBLM. January 2003. 

41

42 BLM. Task 2 Report for the Powder River Basin Coal Review, Past and Present and 

43 Reasonably Foreseeable Development Activities. Prepared for the BLM Wyoming State 

44 Office, BLM Casper Field Office, and BLM Montana Miles City Field Office. Fort Collins, 

45 CO: ENSR Corporation. July 2005a (Revised 2009e). ADAMS Accession No. 

46 ML13014A657. 
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1 BLM. Task 1A Report for the Powder River Basin Coal Review, Current Air Quality Conditions. 

2 Prepared for the BLM Wyoming State Office, BLM Casper Field Office, and BLM Montana Miles 

3 City Field Office. Fort Collins, CO: ENSR Corporation. September 2005b. ADAMS Accession 

4 No. ML13014A730. 

5

6 BLM. Task 1D Report for the Powder River Basin Coal Review, Current Environmental 

7 Conditions. Prepared for the BLM Wyoming State Office, BLM Casper Field Office, and 

8 BLM Montana Miles City Field Office. Fort Collins, CO: ENSR Corporation. June 

9 2005c. 

10

11 BLM. Task 3D Report for the Powder River Basin Coal Review, Cumulative 

12 Environmental Effects. Prepared for the BLM Wyoming State Office, BLM Casper Field 

13 Office, and BLM Montana Miles City Field Office. Fort Collins, CO: ENSR Corporation. 

14 December 2005d. ADAMS Accession No. ML13016A456. 

15

16 BLM. Task 3C Report for the Powder River Basin Coal Review Cumulative Social and 

17 Economic Effects. Prepared for the Wyoming State Office and BLM Casper Field Office. 

18 Fort Collins, CO: ENSR Corporation. December 2005e. ADAMS Accession No. 

19 ML13014A730. 

20

21 BLM. Task 3A Report for the Powder River Basin Coal Review – Cumulative Air Quality Effects. 

22 Prepared for the BLM Wyoming State Office, BLM Casper Field Office, and BLM Montana Miles 

23 City Field Office. Fort Collins, CO: ENSR Corporation. February 2006. 

24

25 BLM. Visual Resource Management. Manual 8400. Washington, DC: USBLM. 2007. 

26

27 BLM. Update of Task 3A Report for the Powder River Basin Coal Review, Cumulative Air 

28 Quality Effects for 2015. Prepared for the BLM Wyoming State Office, BLM Casper Field Office, 

29 and BLM Montana Miles City Field Office. Fort Collins, CO: ENSR Corporation. October 

30 2008a. ADAMS Accession No. ML13016A474. 

31

32 BLM. Final Environmental Impact Statement for the West Antelope II Coal Lease 

33 Application WYW163340. Volumes 1 and 2. Washington, DC: USBLM. December 

34 2008b, 2008c. ADAMS Accession No. ML13016A478. 

35

36 BLM. Update of Task 3A Report for the Powder River Basin Coal Review, Cumulative 

37 Air Quality Effects for 2020. Prepared for the BLM Wyoming State Office, BLM Casper 

38 Field Office, and BLM Montana Miles City Field Office. Fort Collins, CO: ENSR 

39 Corporation. December 2009a. 

40

41 BLM. Summary of the Analysis of the Management Situation Buffalo Resource 

42 Management Plan Revision. Buffalo, WY: USBLM. March 2009b. 

43

44 BLM. Final Environmental Impact Statement for the South Gillette Area Coal Lease 

45 Applications WYW172585, WYW173360, WYW172657, WYW161248. Volumes 1 and 2. 

46 At 

47 http://www.blm.gov/pgdata/etc/medialib/blm/wy/information/NEPA/hpdo/south_gillette/feis.Par

48 .57426.File.dat/vol1.pdf and 
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1 http://www.blm.gov/pgdata/etc/medialib/blm/wy/information/NEPA/hpdo/south_gillette/feis.Par

2 .41361.File.dat/vol2.pdf. BLM. 2009c, 2009d.

3

4 BLM. Update of the Task 2 Report for the Powder River Basin Coal Review Past and Present 

5 and Reasonably Foreseeable Development Activities. Prepared for BLM High Plains District 

6 Office and Wyoming State Office. Fort Collins, CO: AECOM. December 2009e. ADAMS 

7 Accession No. ML13014A657.

8

9 BLM. “Available [GIS] Data, Wyoming.” 2010. At http://www.blm.gov/ 

10 wy/st/en/resources/publicroom/gis/datagis.html (as of April 24, 2012). ADAMS 

11 Accession No. ML13029A247. 

12

13 BLM Environmental Assessment Bentonite Mine Plan of Operation Update to Wyoming Mining 

14 Permit 321C WYW-165212. DOI-BLM-WY-010-EA11-24, BLM Worland Field Office/Wind 

15 River/Bighorn Basin District. Washington, DC: USBLM. June 2011. ADAMS Accession No. 

16 ML13014A670. 

17

18 (US)CB (U.S. Census Bureau). “Profile of General Demographic Characteristics: 2000, 

19 Summary File 1.” 2002. At http://factfinder2.census.gov/faces/tableservices 

20 /jsf/pages/productview.xhtml (as of December 8, 2012). ADAMS Accession No. ML13014A719. 

21

22 (US)CB. “State and County QuickFacts, Wyoming, Crook County, Campbell County.” 2012. At 

23 http://quickfacts.census.gov/qfd/states/56000.html (as of December 8, 2012). 

24

25 CCS (Center for Climate Strategies). Wyoming Greenhouse Gas Inventory and Reference Case 

26 Projections 1990 – 2020. ML13011A261. Washington DC: Center for Climate Strategies. 

27 Spring 2007. 

28

29 CEQ (Council of Environmental Quality). Environmental Justice, Guidance under the National 

30 Environmental Policy Act. Prepared for The Executive Office of the President. Washington, 

31 DC: Government Printing Office. December 1997. ADAMS Accession No. ML13022A298.

32

33 Countess, R., W. Barnard, C. Claiborn, D. Gillette, D. Latimer, T. Pace, and J. Watson. 

34 “Methodology for Estimating Fugitive Windblown and Mechanically Resuspended Road Dust 

Emissions Applicable for Regional Air Quality Modeling” in 10th 35 International Emission Inventory 

36 Conference Proceedings.” Westlake Village, CA: Countess Environmental. May 2001. 

37 ADAMS Accession No. ML13022A448. 

38

39 De Bruin, R. H. Oil and Gas Map of the Powder River Basin, Wyoming. MS-51. Laramie, WY: 

40 Wyoming State Geological Survey. 2007. Accession No. ML13024A167.

41

42 (US)EMC (U.S. Energy Metals Corporation). Application for USNRC Source Material License, 

43 Moore Ranch Uranium Project, Campbell County, Wyoming, Environmental Report. Casper, 

44 WY: Uranium One Americas Corporation. 2007a. ADAMS Accession Nos. ML072851222, 

45 ML072851229, ML072851239, ML07285249, ML07285253, and ML07285255. 

46

47 (US)EMC. Application for USNRC Source Material License, Moore Ranch Uranium Project, 

48 Campbell County, Wyoming, Technical Report. Casper, WY: Uranium 1 Americas Corporation. 
DRAFT Cumulative Impacts

5-54

1 2007b. ADAMS Accession Nos. ML072851222, ML072851258, ML072851259, ML072851260, 

2 ML072851268, ML072851350, and ML072900446. 

3

4 (US)EPA (U.S. Environmental Protection Agency). U.S. EPA Region 8 Climate Change 

5 Strategic Plan, Appendix B, “Summary of State Greenhouse Gas Emissions Inventories in EPA 

6 Region 8, Draft.” Washington, DC: EPA. 2008. ADAMS Accession No. ML13015A528. 

7

8 (US)EPA. Class I Underground Injection Control Program: Study of the Risks Associated with 

9 Class I Underground Injection Wells. EPA 816-R-01-007. Washington, DC: EPA, Office of 

10 Water. March 2001. ADAMS Accession No. ML13015A557. 

11

12 (US)EPA. Protective Noise Levels. Condensed Version of EPA Levels Document. EPA 550/9-

13 79-100. Washington, DC: USEPA. November 1978. ADAMS Accession No. ML13015A552. 

14

15 Ferguson, D. A Class III Cultural Resource Inventory of Strata Energy’s Proposed Ross ISR 

16 Uranium Project, Crook County, Wyoming (Redacted Version). Prepared for Strata Energy, 

17 Inc., Gillette, Wyoming. Butte, MT: GCM Services, Inc. 2010. 

18

19 GCRP (U.S. Global Change Research Program). Global Climate Change Impacts in the United 

20 States. Cambridge, MA: Cambridge University Press. 2009. 

21

22 (US)GS (U.S. Geological Survey). Geodatabase of Wyoming Statewide Oil and Gas Activity to 

23 2010, Version 1, No. DS-625. Denver, CO: USGS. 2011.

24

25 Hinaman, Kurt. Hydrogeologic Framework and Estimates of Ground-Water Volumes in Tertiary 

26 and Upper Cretaceous Hydrogeologic Units in the Powder River Basin, Wyoming. U S. 

27 Geological Survey (USGS) Scientific Investigations Report 2005-5008. Prepared in 

28 Cooperation with the Bureau of Land Management. Reston, VA: USGS. 2005. ADAMS 

29 Accession No. ML13011A278. 

30

31 Langford, Russell H. “The Chemical Quality of the Ground Water” in Harold A. Whitcomb and 

32 Donald A. Morris, Ground-Water Resources and Geology of Northern and Western Crook 

33 County, Wyoming. USGS Water-Supply Paper 1698. Prepared in Cooperation with the State 

34 Engineer of Wyoming. Washington, DC: Government Printing Office. 1964. ADAMS 

35 Accession No. ML13024A154. 

36

37 Naugle, D.E, K.E. Doherty, B. Walker, M.J. Holloran, and H.E. Copeland. 

38 “Energy Development and Greater Sage-Grouse.” Chapter 21, under “Ecology and 

39 Conservation of Greater Sage-Grouse: A Landscape Species and Its Habitats.” Washington, 

40 DC: Studies in Avian Biology. 2009. ADAMS Accession No. ML13024A344.

41

42 National Climate Data Center (NCDC). “Wyoming Climate Summary, Temperature.” 2011a. At 

43 http://www.ncdc.noaa.gov/oa/climate/research/cag3/wy.html (as of November 9, 2011). 

44 ADAMS Accession No. ML13029A254. 

45

46 NCDC. “Wyoming Climate Summary, Precipitation.” 2011b. At 

47 http://www.ncdc.noaa.gov/oa/climate/research/cag3/wy.html (as of December 8, 2012). 

48 ADAMS Accession No. ML13029A270. 
DRAFT Cumulative Impacts

5-55

1 ND Resources. Assessment Restoration Activities, Sundance Project. 1982. ADAMS 

2 Accession No. ML13037A140. 

3

4 Nicholson, C. and Robert L. Wesson. Earthquake Hazard Associated with Deep Well Injection 

5 – A Report to the U.S. Environmental Protection Agency. USGS Bulletin 1951. Denver, CO: 

6 USGS. 1990. ADAMS Accession No. ML13011A329. 

7

8 (US)NRC (U.S. Nuclear Regulatory Commission). NUREG–1748. Environmental Review 

9 Guidance for Licensing Actions Associated with NMSS Programs. Washington, DC: USNRC. 

10 2003. ADAMS Accession No. ML032450279.

11

12 (US)NRC. NUREG–1910. Generic Environmental Impact Statement for In-Situ Leach Uranium 

13 Milling Facilities. Volumes 1 and 2. Washington, DC: USNRC. 2009. ADAMS Accession Nos. 

14 ML091480244 and ML091480188. 

15

16 (US)NRC. NUREG–1910, Supplement 1. Environmental Impact Statement for the Moore 

17 Ranch ISR Project in Campbell County, Wyoming, Supplement to Generic Environmental 

18 Impact Statement for In-Situ Leach Uranium Milling Facilities, Final Report. Washington, DC: 

19 USNRC. August 2010. ADAMS Accession No. ML102290470. 

20

21 (US)NRC. NUREG–1910, Supplement 2. Environmental Impact Statement for the Nichols 

22 Ranch ISR Project in Campbell and Johnson Counties, Wyoming, Supplement to Generic 

23 Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities, Final Report. 

24 Washington, DC: USNRC. January 2011. ADAMS Accession No. ML103440120. 

25 (US)NRC. “Expected New Uranium Recovery Facility Applications/Restarts/Expansions: 

26 Updated February 1, 2013.” 2013. http://www.nrc.gov/materials/uranium-recovery/license27 apps/ur-projects-list-public.pdf (February 25, 2013).

28 Nuclear Dynamics. 1980 Activity and Restoration Report on In Situ Solution Mining Test Site, 

29 Sundance Project Crook County, Wyoming. Source Material License No. SUA-1331, Docket 

30 No. 40-8663. Casper, WY: Nuclear Dynamics. 1980. ADAMS Accession No. ML13038A113. 

31 Powertech, Inc. UIC Permit Application Draft, Class V Injection Wells, Dewey-Burdock Disposal 

32 Wells, Custer and Fall River Counties, South Dakota. Greenwood Village, CO: Powertech, Inc. 

33 March 2010. ADAMS Accession No. ML102380514. 

34

35 Strata (Strata Energy, Inc.). Ross ISR Project USNRC License Application, Crook County, 

36 Wyoming, Environmental Report, Volumes 1, 2 and 3 with Appendices. Docket No. 40-09091. 

37 Gillette, WY: Strata. 2011a. ADAMS Accession Nos. ML110130342, ML110130344, and 

38 ML110130348. 

39

40 Strata. Ross ISR Project USNRC License Application, Crook County, Wyoming, Technical 

41 Report, Volumes 1 through 6 with Appendices. Docket No. 40-09091. Gillette, WY: Strata. 

42 2011b. ADAMS Accession Nos. ML110130333, ML110130335, ML110130314, ML110130316, 

43 ML110130320, and ML110130327. 
DRAFT Cumulative Impacts

5-56

1 Strata. Air Quality Permit Application for Ross In-Situ Uranium Recovery Project. Prepared for 

2 Strata Energy, Inc. Sheridan, WY: Inter-Mountain Laboratories, IML Air Science. 2011c. 

3 ADAMS Accession No. ML11222A060. 

4

5 Strata. Ross ISR Project USNRC License Application, Crook County, Wyoming, RAI Question 

6 and Answer Responses, Environmental Report, Volume 1 with Appendices. Docket No. 40-

7 09091. Gillette, WY: Strata. 2012. ADAMS Accession No. ML121030465. 

8

9 Wyoming (State of Wyoming, Office of the Governor). Greater Sage-Grouse Core Area 

10 Protection. EO No. 2011-5. Cheyenne, WY: State of Wyoming Executive Department. 2011. 

11 ADAMS Accession No. ML13015A702. 

12

13 WSGS (Wyoming State Geological Survey). Powder River Basin Interactive Map. 2012. At 

14 http://ims.wsgs.uwyo.edu/PRB/ (as of December 8, 2012). ADAMS Accession No. 

15 ML13024A347. 

16

17 WDEQ/LQD (Wyoming Department of Environmental Quality/Land Quality Division). “Noncoal 

18 Mine Environmental Protection Performance Standards.” Rules and Regulations, Chapter 3.

19 Cheyenne, WY: WDEQ/LQD. April 2006. 

20

21 WDEQ/LQD. Cumulative Hydrological Impact Assessment of Coal Mining in the Northern 

22 Powder River Basin, Wyoming. WDEQ-CHIA-25. Cheyenne, WY: WDEQ/LQD. April 2010. 

23 ADAMS Accession No. ML13015A591.

24

25 WDEQ/LQD. Cumulative Hydrological Impact Assessment of Coal Mining in the Middle Powder 

26 River Basin, Wyoming. WDEQ-CHIA-27. ML13015A660. Cheyenne, WY: WDEQ/LQD. 

27 2011a. 

28

29 WDEQ/LQD. “Coal Permit Application Requirements.” Rules and Regulations , Chapter 2. 

30 Cheyenne, WY: WDEQ/LQD. 2011b. 

31

32 WDEQ/LQD. 2011. “Environmental Protection Performance Standards for Surface Coal Mining 

33 Operations,” Rules and Regulations, Chapter 4. Cheyenne, WY: WDEQ/LQD. 2011c. 

34

35 WDEQ/WQD (Wyoming Department of Environmental Quality/Land Quality Division). Rio

36 Algom Mining Company. Amendment to Wyoming Underground Injection Control Permit UIC 

37 99-347 for Class I Non-Hazardous Injection Wells Smith Ranch Facility. Cheyenne, WY: 

38 WDEQ/WQD. October 1999. ADAMS Accession No. ML102380514. 

39

40 WDEQ/WQD. Uranium One USA, Inc. Christensen Ranch UIC Class I Injection Well Permit 

41 Number: 10-219. Cheyenne, WY: WDEQ/WQD. November 2010. ADAMS Accession No. 

42 ML103140475. 

43

44 WDEQ/WQD. Strata Energy, Inc. – Ross Disposal Injection Wellfield, Final Permit 10-263,

45 Class I Non-hazardous, Crook County, Wyoming. Cheyenne, WY: WDEQ/WQD. April 2011. 
DRAFT Cumulative Impacts

5-57

1 WWDC (Wyoming Water Development Commission). Northeast Wyoming River Basin Plan, 

2 Final Report. Prepared for WWDC. ML13024A156. Butte, MT: HKM Engineering Inc., Lord 

3 Consulting, and Watts and Associates. 2002a. 

4

5 WWDC. Powder/Tongue River Basin Plan, Final Report. Prepared for WWDC. Butte, MT: 

6 HKM Engineering, Lord Consulting, and Watts and Associates. February 2002b. 

DRAFT Environmental Monitoring

6-1

1 6 ENVIRONMENTAL MEASUREMENTS AND MONITORING 

2

3 6.1 Introduction

4

5 As described in the Generic Environmental Impact Statement (GEIS), monitoring programs are 

6 developed for in situ recovery (ISR) facilities to verify compliance with the applicable standards 

7 and requirements for the protection of worker health and safety in active uranium-recovery 

8 areas (i.e., both the facility and the wellfields) and for protection of the public and the 

9 environment beyond the licensed facility’s boundary (NRC, 2009). Monitoring programs provide 

10 data on operating and environmental conditions so that prompt corrective actions can be 

11 implemented when adverse conditions are detected. It is important to note that the 

12 management of spills and leaks is not considered part of a routine environmental monitoring 

13 program (NRC, 2009). Potential spills and leaks are described in this Supplemental 

14 Environmental Impact Statement’s (SEIS) Section 2.1.1, including the design components and 

15 management techniques that are intended to detect and to minimize the impacts of spills and 

16 leaks.

17

18 This section discusses the types of environmental monitoring activities that the Applicant would 

19 undertake throughout the Ross Project. These include radiological, physiochemical, 

20 meteorological, and ecological monitoring activities. 

21

22 6.2 Radiological Monitoring

23

24 Radiological effluent and environmental monitoring programs are required for an U.S. Nuclear 

25 Regulatory Commission (NRC)-licensed facility. The purpose of the monitoring programs is to 

26 (i) characterize existing levels of radiological materials in the environmental media, (ii) provide 

27 data on measurable levels of radiation and radioactivity in the effluent and environmental media 

28 during the operational life of the facility, and (iii) evaluate principal pathways of radiological 

29 exposure to the public. This section describes Strata’s proposed radiological monitoring 

30 programs for the Ross ISR Project as described in its license application and supporting 

31 documents and subsequent responses to NRC requests for additional information. 

32

33 In accordance with 10 CFR Part 40, Appendix A, Criterion 7, an Applicant is required to 

34 establish a pre-operational monitoring program to establish facility baseline conditions prior to 

35 construction. Results of Strata’s baseline radiological monitoring program are presented in 

36 SEIS Section 3.12.1. After establishing baseline conditions, an ISR facility operator must 

37 conduct an operational monitoring program to measure or evaluate compliance with standards 

38 and environmental impacts of an ISR facility under operational conditions. In accordance with 

39 10 CFR Part 40.65, the license must submit to NRC a semiannual effluent and environmental 

40 monitoring report which would specify the quantity of each of the principal radionuclides 

41 released as effluent or their levels within various environmental media in all unrestricted areas 

42 during the previous 6 months of operation. This report would also provide other NRC required 

43 information to estimate the maximum potential annual radiation doses to the public resulting 

44 from effluent releases.

45

46 The following sections briefly describe the Applicant’s proposed operational monitoring program. 

47 NRC Regulatory Guide 4.14 (NRC, 1980) provides guidance for establishing radioactive effluent 
DRAFT Environmental Monitoring

6-2

1 and environmental monitoring programs for uranium mills, which includes ISR facilities. A 

2 summary of the effluent and environmental monitoring program is presented in Table 6.1.
6-3

1 Table 6.1 Summary of the Major Elements of the Ross Project Operational Environmental Monito

(1)
DRAFT Environmental Monitoring

6-4

1 6.2.1 Airborne Radiation Monitoring

2

3 The Applicant proposes to conduct continuous air particulate sampling at five locations identified 

4 in Figure 6.1. The filters from air samplers will be analyzed on a weekly basis, or more 

5 frequently if required due to dust loading, for natural uranium, Th-230, Ra-226, and Pb-210 in 

6 accordance with Regulatory Guide 4.14 (Strata, 2011a; NRC, 1980). The air samplers will be 

7 calibrated per manufacturer recommendations or at least semiannually with a mass flow meter 

8 or other primary calibration standard (Strata, 2011a). 

9

10 In addition to the air particulate sampling, passive track-etch detectors and thermoluminescent 

11 dosimeters (TLDs) will be deployed at each air particulate monitoring station (Strata, 2011a). 

12 The passive track-etch detectors will provide continuous monitoring of Rn-222 and the detectors 

13 will be exchanged and analyzed on a monthly basis. The TLDs will be used to assess gamma 

14 exposure rates continuously at each air particulate monitoring station. The TLDs will be 

15 exchanged and analyzed on a quarterly basis.

16

17 During operations, Strata will monitor radon gas and passive gamma radiation using Landauer 

18 radon Trak-Etch detectors and environmental low level TLDs at locations shown in Figure 6.1.

19 In total, radon will be monitored at 17 sampling locations, of which five locations are co-located 

20 with the air particulate samplers, as recommended in Regulatory Guide 4.14 (NRC, 1980).

21

22 6.2.2 Soils and Sediment Monitoring

23 The Applicant proposes to collect representative soil samples to a depth of 152 cm (60 in) 

24 annually at each of the five air particulate monitoring stations shown in Figure 6.1. The soil 

25 samples will be collected similar to the baseline collection procedure (i.e., two surficial samples 

26 (to a depth of 15 cm) and two subsurface samples. The samples will be analyzed for natural 

27 uranium, Ra-226, Pb-210 and gross alpha (Strata, 2011a). 

28

29 The Applicant proposes to collect sediment samples annually at the three surface water gaging 

30 stations on Little Missouri River and Deadman Creek and from the Oshoto reservoir. The 

31 sediment sampling at the stream gaging stations will occur during a runoff event between April 

32 and October. The sediment samples will be analyzed for natural uranium, Th-230, Ra-226, and 

33 Pb-210 and gross alpha (Strata, 2011a). 

34

35 The proposed sampling and analyses are consistent with recommendations of Regulatory 

36 Guide 4.14 (NRC, 1980). Similarly, the analytical limits of detection for the soil and sediment 

37 sampling program are consistent with the recommendations of Regulatory Guide 4.14 (NRC, 

38 1980) unless matrix interferences prohibit attainment of these low detection limit goals.

39

40 6.2.3 Vegetation, Food, and Fish Monitoring

41

42 Where a significant pathway to man is identified, Regulatory Guide 4.14 suggests analyzing 

43 three of each type of crop, livestock, etc., raised within 3 km of the ISR site (NRC, 1980). 

44 Vegetation samples should be collected three times during the grazing season, and food and 

45 fish samples should be collected at the time of harvest or slaughter. 
DRAFT Environmental Monitoring

6-5

1

2

3 Source: Figure 3 of Addendum 3.6-A to the environmental report (Strata, 2011a)

4 Figure 6.1

5 Ross Project Meteorological and Baseline Radiological Monitoring Locations
DRAFT Environmental Monitoring

6-6

1 All should be analyzed for Ra-226 and Pb-210. Note (o) in Regulatory Guide 4.14 (NRC, 1980), 

2 Table 2 clarifies that an exposure pathway should be considered important if the predicted dose 

3 to an individual would exceed 5 percent of the applicable radiation protection standard. 

4 Individual members of the public are subject to the dose limits in 10 CFR Part 20.1301. 

5 Pursuant to 10 CFR Part 20.1301, the dose limit is 100 mrem/yr Total Effective Dose Equivalent 

6 (TEDE). 

7

8 The Applicant has established a pre-operational baseline. Based on modeling (i.e., MILDOS9 Area), the Applicant calculates that maximum impacts to the public through all pathways would 

10 be less than 1 percent of the applicable radiation protection standard (Strata, 2011a). 

11 Therefore, because the Applicant has determined that a significant pathway to man does not 

12 exist from these sources, the Applicant does not propose to perform any vegetation, food or fish 

13 sampling during operations (Strata, 2011a). However, the Applicant states that in the event that 

14 monitoring is required, it proposes to follow the protocol used in baseline sampling for three 

15 vegetation samples during the grazing season at three locations at which the model-predicted 

16 concentrations were the highest. The Applicant proposes to collect samples of animal tissue 

17 and fish from the Oshoto Reservoir during site decommissioning. 

18

19 NRC staff includes a license condition for the Applicant to establish a plan for verifying the input 

20 values used in the MILDOS-Area calculations by monitoring the effluent discharges. Should the 

21 effluent discharges invalidate the model calculations, the Applicant will be required to 

22 recalculate the model and/or verify the radiological impacts to the vegetation and food sources 

23 through routine sampling. 

24

25 6.2.4 Surface Water Monitoring

26

27 During the construction phase, the Applicant proposes to conduct a surface water monitoring 

28 program consisting of sampling at the Oshoto reservoir and three on-site stream gaging stations 

29 (SW-1, SW -2 and SW-3) located within Deadman Creek or Little Missouri River (Strata, 2011a). 

30 The Applicant anticipates that, based on the preoperational monitoring program, flows in the 

31 streams will likely be ephemeral primarily during April to October (Strata, 2011a). Surface water 

32 is found year-long in the Oshoto reservoir.

33

34 During operations, the Applicant proposes to conduct a surface water monitoring program which 

35 was conducted during the pre-operational monitoring, i.e., quarterly sampling at three on-site 

36 stream gaging stations and 11 on-site or nearby reservoirs. The parameters to be analyzed for 

37 the operational surface water monitoring program are dissolved and suspended uranium, Th38 230, Ra-226, Po-210 and Pb-210, and, gross alpha and gross beta unless sufficient cause can 

39 be demonstrated to measure a parameter less frequently. 

40

41 The Applicant also commits to monitoring surface water should monitoring be required for a 

42 Wyoming storm water discharge permit through the WYPDES program (Strata, 2011a).

43

44 6.2.5 Groundwater Monitoring

45

46 The Applicant proposes to monitor groundwater quality at the domestic, livestock, and industrial 

47 water supply wells located within a 2 km [1.2 mi] radius of the Ross Project boundary during 

48 both construction and operation phases. The Applicant states that monitoring of the nearby 

49 water supply wells will be conducted quarterly and results provided to NRC on an annual basis. 
DRAFT Environmental Monitoring

6-7

1 The monitoring at a specific water supply well will be contingent upon landowner’s (well 

2 owner’s) consent and, for a variety of reasons (e.g., abandoned, non-functioning pump, 

3 winterized), may not be available every quarter (Strata, 2011a). The parameters to be analyzed 

4 consist of dissolved and suspended uranium, radium-226, thorium 230, lead-210 and polonium5 210, and gross alpha and gross beta. 

6

7 The Applicant estimates that 29 wells exist within 2 km [1.2 mi] of the Ross Project (Strata, 

8 2011a). Based on information in the application, the water supply wells consist of 2 industrial 

9 water supply wells, 15 livestock water supply wells and 12 domestic water supply wells of which 

10 four livestock water supply wells and three industrial wells are located within the Ross Project 

11 area. The proposed monitoring program is a continuation of the pre-operational monitoring 

12 program though the parameters analyzed will be reduced from those analyzed in the pre13 operational monitoring program.

14

15 By license condition, NRC staff will require that nearby water supply wells within 2 km [1.2 mi] of 

16 an active wellfield be sampled in lieu of 2 km [1.2 mi] of the project area. In addition, other 

17 license conditions will require an annual update on the nearby ground water use and require 

18 monitoring of the onsite industrial wells on a monthly basis for the effluent monitoring program if 

19 operations at the industrial wells have not been terminated. 

20

21 6.3 Physiochemical Monitoring

22

23 This section describes the monitoring program proposed by the Applicant that would be initiated 

24 in compliance with applicable environmental regulations and the NRC license. This monitoring 

25 program would allow an evaluation of changes in the chemical and physical environment as a 

26 result of the proposed Ross Project. The physiochemical monitoring program would include 

27 surface water and ground water as well as flow and pressure monitoring of wellfields and 

28 pipelines as described in this section. 

29

30 Pre-licensing, baseline monitoring of surface water and ground water was completed by the 

31 Applicant in 2009 and 2010, and the acquired data were used to characterize the Ross Project 

32 site according to the requirements in 10 CFR Part 40, Appendix A, Criterion 7 (Strata, 2011a). 

33 Sample collection and analysis were performed according to the recommendations found in 

34 NRC’s Regulatory Guide 4.14 (NRC, 1980) as well as the specifications in ASTM D449-85a 

35 (now superseded by ASTM D4448-01), Standard Guide for Sampling Groundwater Monitoring 

36 Wells. In addition, the Applicant also provided supplemental environmental monitoring data in 

37 2012 (Strata, 2012). 

38

39 The surface-water monitoring stations and ground-water monitoring wells established for pre40 licensing baseline monitoring would be incorporated into the post-licensing, pre-operational 

41 data-collection effort and into the active operation-phase environmental-monitoring network.

42

43 6.3.1 Surface-Water-Quality Monitoring

44

45 The Applicant proposes to continue quarterly sampling of the surface-water stations that were 

46 established for pre-licensing baseline water-quality data (Strata, 2011b). The existing surface47 water monitoring stations include the Oshoto Reservoir and three surface-water monitoring 

48 stations; these surface-water stations are located on the Little Missouri River (SW-1 and SW-2) 

49 and on Deadman Creek (SW-3) (see Figure 3.12). The Applicant would add additional stations 
DRAFT Environmental Monitoring

6-8

1 as necessary to meet additional NRC license conditions. Each station is already equipped with 

2 a pressure transducer, a data-logging system, and a runoff-event-activated sampling 

3 mechanism. 

4

5 6.3.2 Ground-Water-Quality Monitoring

6

7 The Applicant proposes a ground-water monitoring program to acquire post-licensing, pre8 operational data in order to establish the parameters (i.e., constituent concentrations) necessary 

9 to detect excursions outside the ore zone during active uranium-recovery operation and to 

10 observe aquifer-restoration performance as it proceeds (Strata, 2011b). The post-licensing, 

11 pre-operational baseline data would be collected from each individual wellfield as it is 

12 completed, but prior to the Applicant’s initiating uranium recovery. Each wellfield’s monitoring 

13 data would be used to establish NRC-approved upper control limits (UCLs) in accordance with 

14 10 Code of Federal Regulations (CFR) Part 40 Appendix A Criterion 5B(5) (i.e., constituent 

15 concentration-based values for excursion detection and aquifer-restoration performance 

16 assessment). Thus, the excursion indicators (or “excursion parameters”) and the aquifer17 restoration target values would be wellfield specific.

18

19 Monitoring wells would be installed in the ore zone to establish post-licensing, pre-operational 

20 baseline water quality for each “mine unit” (i.e., wellfield) (see Figure 2.4 in SEIS Section 2.1.1.). 

21 In addition, monitoring wells would be installed around each wellfield as well as into the 

22 overlying and underlying aquifers. Impending potential excursions to adjacent geologic units 

23 and progress toward meeting aquifer-restoration targets would be monitored by the Applicant’s 

24 sampling designated wells within the wellfields during operation and during aquifer-restoration. 

25 These samples would be analyzed by a laboratory and would yield constituent-concentration 

26 data.

27

28 6.3.2.1 Post-Licensing, Pre-Operational Ground-Water

29 Sampling and Water-Quality Analysis 

30

31 The baseline ground-water monitoring program, which has been used for the last three years at 

32 the Ross Project area, would be expanded from the pre-licensing monitoring wells installed for 

33 site characterization, to a program designed to generate data specific to a mine unit, as needed. 

34 This program would be codified in the NRC license. The post-licensing, pre-operational 

35 monitoring program would provide data to establish UCL constituent concentrations that would 

36 be used by the Applicant to identify potential horizontal excursions of lixiviant outside of a 

37 wellfield and potential vertical excursions into the overlying or underlying aquifers (Strata, 

38 2011b). The spacing, distribution, and the number of monitoring wells would be site specific 

39 and would be codified in the NRC license (NRC, 2009).

40

41 The Applicant proposes the installation of one well cluster for every four wellfield acres for their 

42 post-licensing, pre-operational data-collection program, which is consistent with the range the of 

43 one well per 0.4 ha [1 ac] to one well per 1.62 ha [4 ac] in the GEIS and the SRP (NRC, 2009, 

44 2003), and historically used at existing ISR facilities. At the time of preparation of this 

45 manuscript, NRC staff has developed a draft license condition to require a minimum density of 

46 one well per 0.8 ha [2 ac] for the Commission-approved background based on staff’s evaluation 

47 of site-specific geologic and hydrogeologic conditions, and the applicant’s proposed sequencing 

48 and area of individual wellfield modules. 
DRAFT Environmental Monitoring

6-9

1 The Ross Project would include approximately 45 wells completed in the ore aquifer (30 – 55 m 

2 [100 – 180 ft]-thick sand interval) in the lower Lance/Upper Fox Hills Formations (designated as 

3 the ore-zone [OZ] unit) to establish baseline data. At approximately half of those location (24 

4 locations), an additional well will be completed in the underlying aquifer (3 – 9 m [10 – 30 ft] 

5 thick sandy interval in the Fox Hills Formation (designated as the deep-monitoring [DM] unit 

6 below the ore zone) and the overlying lying aquifer in the first water-bearing unit above all 

7 mineralized zones in the Lance Formation (designated as the SM unit) forming a three-well 

8 cluster at those locations. The wells completed in the SM and DM units would use a fully 

9 penetrating completion while the ore-zone wells would target specific roll fronts (see Figures 2.8 

10 – 2.10). Beyond the six existing well clusters used for pre-licensing baseline monitoring and site 

11 characterization, the Applicant proposes no additional surficial-aquifer (SA) wells for the wellfield 

12 areas; however, by license condition, the Applicant would be required to monitor the uppermost 

13 SA aquifer for wellfields which overly the SA aquifer that is found at shallow depths and is 

14 comprised of alluvial deposits associated with the recent stream channels.

15

16 For post-licensing, pre-operational water-quality characterization of the wellfields, the Applicant

17 proposes to obtain at least four samples, with a minimum of two weeks between sampling 

18 events, for all perimeter, SM, OZ, and DM baseline wells. In addition, the SA-well network 

19 would continue to be sampled on a quarterly basis through the wellfield data-acquisition phase 

20 before final licensing for uranium recovery. The first and second sampling events would include 

21 laboratory analyses for constituents listed in GEIS Table 8.2-1 (NRC, 2009). The Applicant also 

22 proposes a reduced list of constituents for the third and fourth sampling events, which would be 

23 informed by the results of the previous two sampling events. Results from the sample analyses 

24 would be averaged arithmetically to obtain an average value as well as a maximum value for 

25 use in the NRC’s determination of UCLs for excursion detection. The Applicant’s proposed 

26 monitoring program would be modified as required by the NRC license.

27

28 6.3.2.2 Operational Ground-Water Sampling and Water-Quality Analysis

29

30 As described in GEIS Section 8.3.1.2, the placement of monitoring wells would occur around the 

31 perimeter of wellfields, in the aquifers both overlying and underlying the ore zone, and within the 

32 ore-zone aquifer for the early detection of potential horizontal and vertical excursions of lixiviant

33 (NRC, 2009). The spacing, placement, and number of monitoring wells would be site-specific 

34 and would be established by the NRC in its license to the Applicant (NRC, 2009). 

35

36 Three configurations of monitoring wells would be constructed to ensure detection of horizontal 

37 and vertical excursions: wells through the entire targeted ore zone (i.e., the ore body) at the 

38 perimeters of the wellfields; wells completed in the aquifer underlying the ore zone; and wells 

39 completed in the aquifer overlying the ore zone (Strata, 2011b). The design of a typical 

40 monitoring well is described in SEIS Section 2.1.1 (see also Figures 2.8 – 2.10). To detect 

41 whether an excursion of lixiviant has occurred, the monitoring results would be compared 

42 against the NRC-approved UCLs. 

43

44 The Applicant proposes well spacing that meets the minimum requirement described in the 

45 GEIS as necessary to detect excursions (NRC, 2009). However, NRC staff has developed a 

46 draft license condition to require a minimum density of one well per 0.8 ha [2 ac] for the 

47 Commission-approved background based on NRC staff’s evaluation of site-specific geologic 

48 and hydrogeologic conditions, and the applicant’s proposed sequencing and area of individual 

49 wellfield modules. Wells completed in the aquifer underlying the ore zone and in the aquifer 
DRAFT Environmental Monitoring

6-10

1 overlying the ore zone would be installed at a density of one well per 1 – 2 ha [3 – 4 ac] of 

2 wellfield to detect vertical migration. The Applicant proposes a spacing of the perimeter 

3 monitoring wells of 120 – 180 m [400 – 600 ft] apart and at a distance of approximate 120 – 180 

4 m [400 – 600 ft] from the edge of the wellfield to detect potential horizontal excursions. 

5 Simulations by the Applicant demonstrate that the proposed well spacing successfully detects 

6 hydraulic anomalies in the form of water-level increases well before lixiviant has actually moved 

7 beyond the active uranium-recovery areas (Strata, 2011b). 

8

9 The Applicant proposes that samples from these monitoring wells would be collected every two 

10 weeks to be analyzed for the excursion parameters (i.e., constituents) (Strata, 2011b). In 

11 addition, dedicated pressure transducers and/or in situ water-quality instruments would be used 

12 in the perimeter monitoring wells to provide early detection of potential excursions or hydraulic 

13 anomalies. Water levels would be routinely measured during well sampling in the perimeter, 

14 overlying, and underlying monitoring wells in order to provide an early warning for impending 

15 wellfield problems. An increasing water level in a perimeter monitoring well has been shown to 

16 be an indication of a local-flow imbalance within the wellfield, which could result in a lixiviant 

17 excursion. An increasing water level in an overlying or underlying monitoring well could similarly 

18 be caused by the migration of lixiviant from the ore-zone aquifer, or it could indicate an injection 

19 well-casing failure. This monitoring would allow immediate corrective actions, thus reducing the 

20 likelihood of excursions.

21

22 6.3.3 Flow and Pressure Monitoring of Wellfields and Pipelines

23

24 In GEIS Section 8.3.2, the monitoring of flow rates and pressures of lixiviant pumped to injection 

25 wells and from recovery wells is described. These monitoring data would be used by the 

26 Applicant to manage the water balance for the entire wellfield and to maintain an inward 

27 gradient to reduce the likelihood of excursions (NRC, 2009). To manage the water balance at 

28 the Ross Project, the Applicant proposes flow meters and pressure transmitters on each of the 

29 pipelines between the module building and injection and recovery wells. All instrumentation 

30 would be monitored at the module building and at the central processing plant (CPP). The 

31 wellfield flows would be balanced based on the module injection and recovery feeder-line 

32 meters. An individual well’s flow targets would be determined on a per-well-pattern basis to 

33 ensure that local wellfield areas are balanced on at least a weekly basis. The maximum 

34 injection pressure would be less than the formation’s fracture pressure. 

35

36 Each module building would have the capability of being isolated from the pipelines by manually 

37 operated butterfly valves contained in the manholes exposing the pipelines. The manholes 

38 would have leak-detection devices that would activate an audible and visible alarm at the CPP 

39 in the event of a leak. Pressure transmitters on each end of the trunk lines and feeder lines 

40 would relay pressure readings back to the CPP’s control room. In the event of a pressure 

41 reading that is outside of acceptable operating parameters, an audible and visible alarm would 

42 occur at the CPP. Automatic sequential shutdown of the trunk-line pumps and/or module43 building booster pumps and recovery-well pumps would then occur if operating parameters do 

44 not return to normal ranges within a specified amount of time. 

45

46 6.4 Meteorological Monitoring

47

48 The Applicant proposes to continue operating the meteorological monitoring station installed in 

49 January 2010 as part of its site-characterization baseline monitoring program (Strata, 2011a). 
DRAFT Environmental Monitoring

6-11

1 The data collected at this station would include continuous measurements of wind speed, wind 

2 direction, temperature, relative humidity, precipitation, and evaporation.

3

4 6.5 Ecological Monitoring

5

6 Ecological monitoring would include both vegetation and wildlife surveys.

7

8 6.5.1 Vegetation Monitoring

9

10 The Applicant proposes to monitor all disturbed areas on the Ross Project area for the presence 

11 of undesirable (i.e., noxious or invasive) species and to use control measures to prevent their 

12 spreading. Vegetation monitoring in reclaimed areas would be conducted according to U.S. 

13 Bureau of Land Management (BLM) and Wyoming Department of Environmental Quality 

14 (WDEQ) requirements and would be in accordance with the decommissioning requirements that 

15 would be included in the Applicant’s NRC license (Strata, 2011a). Revegetation success would 

16 be monitored by the “extended reference area” concept, as defined in WDEQ/Land Quality 

17 Division (LQD), Guideline No. 2 (Strata, 2011a). The extended reference area would include all 

18 of the undisturbed portions of any vegetation type which has experienced disturbance in any 

19 phase of the Ross Project. At the end of decommissioning, quantitative vegetation data for 

20 extended reference areas representing each disturbed vegetation type would be directly 

21 compared by statistical analysis to quantitative vegetative data from reclaimed vegetation types. 

22 The duration of vegetation monitoring, and the target goals, would be defined in the final 

23 decommissioning plan required by the NRC license.

24

25 6.5.2 Wildlife Monitoring

26

27 The Applicant proposes annual wildlife surveys in and near the Ross Project area throughout 

28 the lifecycle of uranium-recovery activities in order to document key wildlife species, population 

29 trends, and habitats (Strata, 2011a). 

30

31 6.5.2.1 Annual Reporting and Meetings

32

33 The Applicant would coordinate its wildlife-monitoring program with the BLM’s Newcastle Field 

34 Office and the Wyoming Game and Fish Department (WGFD). Consultation with the U.S. Fish 

35 and Wildlife Service (USFWS), BLM, and WGFD would be conducted prior to the Applicant’s 

36 initiating a survey and would be documented in a work plan, with BLM and WGFD concurrence. 

37 The Applicant would prepare an annual monitoring report and submit it to the BLM, WGFD, and 

38 other interested parties by November 15 of each year. The monitoring report would include:

39

40 ■ Survey methods and results as well as observations of any trends and assessments of 

41 wildlife-protection measures implemented during the past year; 

42 ■ Recommendations for changes in wildlife-protection measures for the coming year;

43 ■ Recommendations for modifications to wildlife monitoring or surveying; and

44 ■ Recommendations for additional species to be monitored (e.g., a newly Federal- or State45 listed species). 
DRAFT Environmental Monitoring

6-12

1 Data and mapping would be formatted to meet BLM requirements (i.e., geographic information

2 systems data and maps). 

3

4 6.5.2.2 Annual Inventory and Monitoring

5

6 Wildlife surveying and monitoring would be performed by BLM or WGFD biologists or a qualified 

7 scientist under contract to the Applicant. All aspects of a regular and/or periodic monitoring 

8 program would be developed according to current regulatory and permitting guidelines and 

9 requirements. These would include field-survey and survey-equipment requirements; data 

10 collection, analysis, reporting, and storage procedures; agency consultations and collaborations; 

11 and any other relevant survey- and monitoring-program components.

12

13 6.5.2.3 Wildlife Species

14

15 Mammals and certain birds as well as all wildlife on the BLM Sensitive Species (BLMSS), 

16 WSOC, and USFWS’s SMC lists at the Ross Project area would be monitored in the Applicant’s 

17 wildlife monitoring program.

18

19 Mammals

20

21 Opportunistic observations of all wildlife species would be conducted in late spring and summer, 

22 during the Applicant’s completion of the surveys discussed below for sensitive species. No big23 game crucial ranges, habitats, or migration corridors are recognized by the WGFD at the Ross 

24 Project area or the surrounding 1.6-km [1-mi] perimeter. A “crucial” range or habitat is defined 

25 as any particular seasonal range or habitat component that has been documented as the 

26 determining factor in a population's ability to maintain and reproduce itself at a certain level. 

27 Due to the lack of crucial big-game habitats, the WGFD did not require big-game surveys during 

28 pre-licensing baseline monitoring the Applicant performed in 2009 and 2010 (Strata, 2011a). 

29 Long-term monitoring for big game is not anticipated and has not been proposed by the 

30 Applicant.

31

32 Protected Species and Other Birds

33

34 The Applicant proposes to monitor protected species, using the following strategy (Strata, 

35 2011a):

36

37 ■ Early spring surveys for and monitoring of sage-grouse leks within 2 km [1.2 mi] of the Ross 

38 Project area. All threatened and endangered species as well as those on the BLMSS, 

39 Wyoming Species of Concern (WSOC), and USFWS’s “Migratory Bird Species of 

40 Management Concern in Wyoming” (SMC) lists would be surveyed and monitored on the 

41 Ross Project area as well. 

42 ■ Late spring and summer opportunistic observations of all wildlife species, including 

43 threatened, endangered, BLMSS, WSOC, SMC, and any other species of concern would 

44 occur and noted.

45 ■ Any other surveys as required by regulatory agencies.

46
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6-13

1 Raptors

2

3 Only one raptor’s nest was previously identified on the Ross Project area, and the opportunity 

4 for nesting is limited in the area due to a lack of suitable habitat (i.e., trees and cliffs). However, 

5 the Applicant has committed to completing the following:

6

7 ■ Early-spring surveys for new and/or occupied raptor territories and/or nests, and

8 ■ Late-spring and summer surveys for raptor reproduction at occupied nests. 

9

10 The nearest human disturbance to active and inactive raptor nests, any visual barriers in the line 

11 of sight of raptor nests, and the prey abundance (e.g., jackrabbits and cottontails) would be 

12 reported in each annual report to allow an assessment of whether any raptor disturbance is 

13 related to uranium-recovery activities.

14

15 Migratory Birds

16

17 The Applicant would conduct nesting-bird surveys for nongame species during early summer, 

18 following recommended WDEQ techniques. All birds, observed or heard, and the vegetation 

19 and habitat type where they might be found would be recorded. These surveys would 

20 document all high-interest bird species identified by the BLM, WGFD, and USFWS.

21

22 6.6 References

23

24 10 CFR Part 20. Title 10, “Energy,” Code of Federal Regulations, Part 20 “Standards for 

25 Protection Against Radiation.” Washington, DC: U.S. Government Printing Office. 

26

27 (US)NRC (U.S. Nuclear Regulatory Commission). Radiological Effluent and Environmental 

28 Monitoring at Uranium Mills, Revision 1. Regulatory Guide 4.14. Washington, DC: NRC. 

29 1980. ADAMS Accession No. ML003739941. 

30

31 (US)NRC. Generic Environmental Impact Statement for In-Situ Leach Uranium Milling 

32 Facilities, Volumes 1 and 2. NUREG–1910. Washington, DC: NRC. 2009. 

33 ADAMS Accession Nos. ML091480244 and ML091480188. 

34

35 Strata (Strata Energy, Inc.). Ross ISR Project USNRC License Application, Crook County, 

36 Wyoming, Environmental Report, Volumes 1, 2 and 3 with Appendices. Docket No. 40-09091. 

37 Gillette, WY: Strata. 2011a. Agencywide Documents Access and Management System 

38 (ADAMS) Accession Nos. ML110130342, ML110130344, and ML110130348. 

39

40 Strata. Ross ISR Project USNRC License Application, Crook County, Wyoming, Technical 

41 Report, Volumes 1 through 6 with Appendices. Docket No. 40-09091. Gillette, WY: Strata. 

42 2011b. ADAMS Accession Nos. ML110130333, ML110130335, ML110130314, ML110130316, 

43 ML110130320, and ML110130327. 

44

45 Strata. Ross ISR Project USNRC License Application, Crook County, Wyoming, RAI Question 

46 and Answer Responses, Environmental Report, Volume 1 with Appendices. Docket No. 40-

47 09091. Gillette, WY: Strata. 2012. ADAMS Accession No. ML121030465. 

DRAFT Cost-Benefit Analysis

7-1

1 7 COST-BENEFIT ANALYSIS

2

3 This section summarizes the benefits and costs associated with the Proposed Action and the 

4 two Alternatives. The discussion of costs and benefits follow the U.S. Nuclear Regulatory 

5 Commission (NRC) guidance presented in NUREG–1748 (NRC, 2003). The discussion of the 

6 costs and benefits include both the costs of each Alternative and a qualitative discussion of 

7 environmental impacts, as applicable.

8

9 7.1 Proposed Action

10

11 Benefits of the Proposed Action include the additional employment opportunities available to 

12 area residents, increased incomes to area residents, and additional tax revenues accruing to 

13 local jurisdictions and the State of Wyoming. Potential costs include both the internal costs of 

14 the Ross Project borne by the Applicant and the potential external monetary costs that may be 

15 required by local public-service providers in response to Project activities as well as non16 monetary costs associated with the potential environmental impacts.

17

18 7.1.1 Ross Project Benefits

19

20 The economic benefits of the Ross Project would be positive for Crook County and generally 

21 positive for residents directly or indirectly affected by the Project. The Applicant is committed to 

22 hire local personnel and to make equipment purchases at local suppliers whenever possible 

23 (Strata, 2012), maximizing the economic benefits to Crook County and neighboring counties.

24

25 7.1.1.1 Employment and Income

26

27 The Ross Project is expected to require a peak workforce of approximately 200 workers during 

28 its construction phase; 60 workers during operation; 20 – 30 workers during the aquifer29 restoration phase; and 90 workers for decommissioning activities (see Supplemental 

30 Environmental Impact Statement [SEIS] Section 4.11). This employment would be beneficial 

31 because it would reduce the local unemployment rate for the duration of construction, and some 

32 workers would likely stay through the operation phase of the Ross Project. It is expected that 

33 workers would be paid the regional rates typical of Crook and Campbell Counties, where a 

34 higher percentage of jobs are in the relatively higher-paying energy industry. Based upon 

35 weighted average annual earnings per job of $61,400 (see SEIS Section 3.11), earnings 

36 accruing to area residents would range from $1.2 million to $1.8 million during the aquifer37 restoration phase to approximately $12.3 million during the Ross Project’s construction phase. 

38 In addition, existing private-property landowners at the Ross Project area would be 

39 compensated for the loss of use of their land; however, the specific terms of this compensation 

40 is unknown.

41

42 7.1.1.2 Tax Revenues

43

44 Average annual tax revenues are estimated to be $2,785,000 per year during the Ross Project’s 

45 operation (see Section 4.11.1) and would total $27,850,000 over the lifecycle of the Project. 

46 The State of Wyoming would benefit, in part, from the severance and royalty payments, 

47 estimated to be $10.9 million over the lifecycle of the Ross Project, whereas Crook County 

48 would benefit from the gross production and property taxes, totaling $16.9 million over the 
DRAFT Cost-Benefit Analysis

7-2

1 lifecycle of the Project. In addition, some portion of the State severance and royalty payments 

2 would be distributed among all Wyoming cities and counties and, thus, all jurisdictions within the 

3 State are expected to benefit from increased State tax revenues (WLSO, 2010).

4

5 7.1.2 Ross Project Costs

6

7 Potential costs include both the internal costs of the project borne by the Applicant and potential 

8 external costs that may be required by local public service providers in response to project 

9 activities, as well as non-monetary costs associated with the potential environmental impacts.

10

11 7.1.2.1 Internal Costs

12

13 All internal costs would be borne by the Applicant—that is, the direct financial costs of the 

14 construction, operation, aquifer restoration, and decommissioning of the proposed Ross Project. 

15 The primary internal costs would include: 

16

17 ■ Capital costs associated with the Applicant’s obtaining land and mineral rights as well as 

18 securing regulatory approvals including permits, licenses, and related environmental 

19 studies

20 ■ Capital costs of facility and wellfield construction

21 ■ Costs of facility and wellfield operation and maintenance

22 ■ Costs of aquifer restoration

23 ■ Costs of facility and wellfield decontamination, dismantling, and decommissioning

24 ■ Costs of site reclamation and restoration

25

26 The Applicant estimates that these internal costs would be approximately $136.7 million (Strata, 

27 2011a). The actual, estimated decommissioning costs for the Ross Project would be 

28 determined prior to Project operation, and a surety arrangement equal to the estimated 

29 decommissioning costs would be made a condition of the NRC license. Each year, the 

30 decommissioning cost estimate would be reviewed by the NRC and Wyoming Department of 

31 Environmental Quality (WDEQ), and adjustments would be made as necessary. 

32

33 7.1.2.2 External Costs

34

35 Land Use

36

37 During the Proposed Action, impacts to local land use would occur. Impacts would result from 

38 land disturbances during construction and decommissioning, grazing and access restrictions, 

39 and competition for access to mineral rights. Land use impacts during all phases of the Project 

40 would be SMALL. Access restrictions at the Ross Project area, however, would preclude the 

41 economic benefits from existing agricultural and grazing activities. If site access is assumed to 

42 be restricted across the entire Ross Project area—696 ha [1,721 ac]—and based upon a market 

43 value of products sold from crop and livestock sales in Crook County averaging $28 per acre in 

44 2007 dollars (USDA, 2009), $48,188 in annual lost-agriculture sales would be estimated as the 

45 upper end of this potential loss, or $481,880 over the lifecycle of the Project. These losses 
DRAFT Cost-Benefit Analysis

7-3

1 would be offset by the compensation paid to the landowners, where the exact terms of the 

2 respective compensation is confidential. 

3

4 Transportation

5

6 During the Proposed Action, the highest traffic volume would occur during the construction 

7 phase because of the relatively large workforce as well as the increased demand for materials 

8 and equipment at the Project area. The increased traffic is expected to be 400 passenger cars 

9 and 24 trucks per day, which, compared to 2010 levels, represents a significant traffic volume 

10 increase of approximately 400 percent on New Haven Road. Thus, construction-phase 

11 transportation impacts would be MODERATE to LARGE with respect to the traffic levels on local 

12 roads and the road surfaces, and SMALL with respect to traffic levels on I-90. All other phases 

13 would have less traffic related to commuting workers and, thus, the impacts would range from 

14 SMALL to LARGE. This traffic could result in more traffic accidents as well as wear and tear on 

15 road surfaces. Mitigation measures would be in place and would reduce the range of these 

16 impacts to SMALL to MODERATE. 

17

18 Geology and Soils

19

20 Under the Proposed Action, potential impacts to geology and soils would occur due to the 

21 disturbance of 113 ha [280 ac] of the Ross Project area, or about 16 percent (Strata, 2011b). 

22 Other soil impacts would include the Applicant’s clearing of vegetation; stripping of topsoil; 

23 excavating, backfilling, and compacting soil; grading of the land; and trenching for utilities and 

24 pipelines. There is limited potential impact to geology because of the minor depth of 

25 disturbance associated with construction of the Ross Project. The potential impacts from soil 

26 loss would be minimized by proper design and operation of surface-runoff features and 

27 implementation of best management practices (BMPs). Impacts to geology and soils would be 

28 SMALL.

29

30 Water Resources

31

32 The Ross Project has the potential to impact surface water and ground water during each phase 

33 of its lifecycle.

34

35 Surface Water

36

37 Under the Proposed Action, surface-water-related impacts would include potentially increased 

38 sediment concentrations. Depending upon discharge rates and locations, impacts from the 

39 discharge of water generated during aquifer testing, during well installation and pipeline integrity 

40 testing, and during the dewatering of the facility areas inside of the containment barrier wall 

41 (CBW), surface-water impacts would be SMALL. Stream-channel disturbance, surface-water 

42 contamination, and surface-water consumptive use impacts would be SMALL. Impacts to 

43 surface water would also include the potential contamination of surface water by a spill or 

44 unintended release of process solutions, which could result in SMALL impacts with mitigation. 

45 Finally, reduced flows, in particular, the Little Missouri River would be a SMALL impact. 
DRAFT Cost-Benefit Analysis

7-4

1 Ground Water

2

3 Under the Proposed Action, potential impacts to ground water are primarily from the 

4 consumptive use of ground water (i.e., removing more than is injected in), disposal of drilling

5 fluids and cuttings during well drilling, and spills and leaks of fuels and lubricants from 

6 construction equipment. Impacts to shallow (i.e., near-surface) aquifers would be SMALL. The 

7 impacts to the ore-zone and surrounding aquifers regarding the quantity of water available 

8 would also be SMALL to MODERATE, while the potential impact of improperly abandoned 

9 drillholes, over-penetration of holes, or well integrity could result SMALL to MODERATE water10 quality impacts in the event of an excursion in a Ross Project wellfield and SMALL elsewhere. 

11

12 Ecology

13

14 Under the Proposed Action, potential environmental impacts to ecological resources, both flora 

15 and fauna, could occur during all phases of the Project; all impacts would be SMALL. The 

16 impacts to local vegetation would include:

17

18 ■ Removal of vegetation from the Ross Project area

19 ■ Modification of existing vegetative communities

20 ■ Loss of sensitive plants and habitats

21 ■ Potential spread of invasive species and noxious weed populations

22 ■ Reduction in wildlife habitat and forage productivity

23 ■ Increased risk of soil erosion and weed invasion

24

25 Impacts to terrestrial wildlife could include:

26

27 ■ Loss, alteration, or incremental fragmentation of habitat

28 ■ Displacement of and stresses on wildlife

29 ■ Direct and/or indirect mortalities

30

31 Aquatic species could be affected by:

32

33 ■ Disturbances of stream channels

34 ■ increases in suspended sediments 

35 ■ Pollution from spills and leaks 

36 ■ Reduction of habitat

37

38 These impacts would be mitigated by, for example, implementing the standard management 

39 practices required or suggested by the Wyoming Game and Fish Department (WGFD). All 

40 ecological resource impacts would be SMALL.
DRAFT Cost-Benefit Analysis

7-5

1 Air Quality

2

3 Under the Proposed Action, impacts from nonradiological particulate emissions would primarily 

4 result from fugitive road dust created by moving vehicles and mobile equipment throughout the 

5 Ross Project area and, to a far lesser extent, the processes and circuits implemented in the 

6 Central Processing Plant (CPP). Combustion-engine emissions from diesel-equipment 

7 operation would occur primarily during the construction, operation, and decommissioning 

8 phases. In general, however, uranium-recovery activities are not major air-emission sources. 

9 Air-quality impacts during all phases of the Ross Project would be SMALL.

10

11 Noise 

12

13 Under the Proposed Action, there would be very temporary, but MODERATE, noise impacts for 

14 residences very near the Ross Project area; for residences, communities, or sensitive areas that 

15 are located more than approximately 300 m [1,000 ft] from specific noise-generating activities 

16 the impacts would be SMALL because noise levels quickly decrease with distance. These 

17 impacts would be the result of uranium-recovery activities and the associated traffic that would 

18 be associated with the Ross Project. During high truck-traffic events on New Haven Road 

19 during all phases of the Ross Project, residents living on those routes could occasionally be 

20 annoyed by the noise. There are no churches, schools, or community centers located less than 

21 300 m [1,000 ft] from the Ross Project’s boundary. Impacts to workers at the Project also would 

22 be SMALL because of the Applicant’s compliance with OSHA noise regulations. 

23

24 Historical, Cultural, and Paleontological Resources

25

26 The costs and benefits of the Ross Project related to historic, cultural, and paleontological 

27 resources will be determined once a complete inventory of these resources within the Ross 

28 Project area has been completed.

29

30 Visual and Scenic Resources

31

32 Under the Proposed Action, MODERATE, short-term impacts to the visual and scenic resources 

33 of the area during construction would occur, and SMALL longer-term impacts for the remainder 

34 of the Ross Project (see SEIS Section 4.10). Potential visual and scenic impacts would result 

35 from the surface disturbance and construction of the following: 1) wellfields (including drill rigs, 

36 header houses, wellhead covers, and roads; 2) the CPP; 3) surface impoundments; 4) the 

37 CBW; 5) secondary and tertiary access roads; 6) power lines; and 7) fencing. The nearest 

38 protected visual resource to the Ross Project is the Devils Tower National Monument, which is 

39 approximately 16 km [10 mi] east of the Ross Project. Although the Project itself would not be 

40 visible at the lower park portion of the Tower, climbers ascending to the top of the Tower may 

41 be able to see some of the Project’s largest attributes as well as, in the night sky, the lights of 

42 the Project. The visual impacts from the Ross Project would be consistent with the U.S. Bureau 

43 of Land Management’s (BLM’s) VRM Class III designation (NRC, 2009). 

44

45 The degradation of views of the nighttime sky in the surrounding vicinity of the Project area has 

46 been evaluated using the contingent valuation method (CVM) at four national parks (i.e., 

47 Yellowstone, Great Basin, Mesa Verde, and Chaco Canyon) during summer surveys in 2007 

48 (Mitchell et al., 2008). These surveys were designed to quantify the willingness-to-pay (WTP) to
DRAFT Cost-Benefit Analysis

7-6

1 reduce light pollution in these areas. Over 50 percent of respondents were willing to pay a 

2 positive amount to address light pollution. The average amount individuals would be willing to 

3 increase their Federal tax to reduce light pollution was estimated to be $39.37 per year per 

4 person. When the self-reported survey characteristics are reviewed, there is a positive 

5 correlation between the extent individuals are exposed to light pollution and their willingness to 

6 pay to reduce it. Hence, people in rural areas are generally less willing to pay to reduce light 

7 pollution. There are 11 residences within Ross Project area where visual-resource impacts 

8 were evaluated (see SEIS Section 4.10). Based on an average household size of 2.41 persons 

9 per household in Crook County (USCB, 2012), an estimated 27 persons could be affected by 

10 light from the Project, and the external costs associated with light pollution would be $1,063 per 

11 year or $10,630 over the lifecycle of the Ross Project. 

12

13 Socioeconomics

14

15 Under the Proposed Action, the impacts of the Ross Project on the demand for community 

16 services are projected to be small (see SEIS Section 4.11.1.1). The Applicant is committed to 

17 hiring locally and, during peak construction-phase activities, it is projected only 52 additional 

18 residents are expected in the ROI (i.e., Crook and Campbell Counties). Lower demographic

19 impacts occur in subsequent Project phases. Ross Project-related population increases would 

20 represent less than 0.1 percent of the 2010 population in the two-county ROI and, in general, 

21 existing community-service providers, such as local schools, health-service agencies, and 

22 police and fire-protection agencies, are not expected to be adversely affected by this level of 

23 increased demand for public services.

24

25 There would be an increased need, however, for emergency-response services. The Applicant

26 has entered into a Memorandum of Understanding (MOU) with Crook County (Strata and Crook 

27 County, 2011) that states the Applicant would coordinate emergency-management, hazardous28 materials management, and fire-suppression planning with Crook County’s Homeland Security 

29 Director and Crook County’s Fire Warden and Fire Zone Warden. The Applicant commits to 

30 maintaining the onsite personnel and equipment necessary to provide emergency services 

31 when environmental, safety, or health emergencies arise at the Ross Project. As such, these 

32 services would not represent a cost to local governments (Strata and Crook County, 2011).

33

34 The MOU also states the Applicant would:

35

36 ■ Provide electronic warning signs that would close county roads into the Ross Project area in 

37 the case of an emergency.

38 ■ Provide dust control for the existing and increased traffic as a result of the Ross Project, as 

39 necessary, and, as required by the WDEQ. This would include dust control over each one40 quarter mile of county roads fronting the residences along any road designated by the 

41 County as an access road to the Ross Project, in order to minimize dust impacts on area 

42 residents beyond the Ross Project area.

43 ■ Maintain and repair damage caused by Applicant’s trucks or contracted trucks as a result of 

44 their use, as dictated and regulated by Crook County (Strata and Crook County, 2011).

45 These measures would minimize any costs that would be borne by local jurisdictions and area 

46 residents. 
DRAFT Cost-Benefit Analysis

7-7

1 Environmental Justice

2

3 Under the Proposed Action, no minority or low-income populations have been identified in the 

4 Ross Project area. Therefore, there are no disproportionately high and adverse impacts to 

5 minority and low-income populations by the Ross Project.

6

7 Public and Occupational Health and Safety

8

9 Under the Proposed Action, potential nonradiological and radiological impacts to the public’s 

10 and workers’ health and safety over the course of the Ross Project could include accidental 

11 chemical or radiological releases, chemical or byproduct liquid spills, particulate and gaseous 

12 emissions, vehicular and equipment accidents, worker injuries and illnesses, or fires. The 

13 Applicant proposes to minimize these potential impacts through rigorous worker training, facility 

14 and wellfield design, operational controls, and a series of emergency-response protocols. 

15

16 An important factor in the assessment of risks to public health and safety is the proximity of 

17 potentially impacted populations. The nearest incorporated community to the Ross Site is 

18 Moorcroft, Wyoming, with an estimated population of less than 1,000; Moorcroft is located 

19 approximately 35 km [22 mi] south of the Ross Project area. Unincorporated Oshoto is adjacent 

20 to the Ross Project area, but it has a population of fewer than 50 persons. In addition, the 

21 quantities of materials that could be released, even through the air pathway, would be small 

22 and, as discussed in SEIS Section 4.7, would be dispersed and diluted. Workers involved in the 

23 response and cleanup of spills and leaks could receive MODERATE impacts; these would be 

24 mitigated by establishing standard operating procedures (SOPs) and training requirements. 

25 Thus, little to no risk would be borne to the offsite public, and these impacts would be 

26 considered SMALL.

27

28 Waste Management

29

30 Under the Proposed Action, both liquid and solid wastes would be generated during all phases 

31 of the Ross Project’s lifecycle. Several major waste streams are identified in SEIS Section 4.14. 

32 At least four of these waste streams have to the potential to impact the local communities. 

33

34 The disposal of liquid byproduct wastes would be accomplished by injection of these wastes into 

35 a confined aquifer. The regulatory-permitting process for this type of waste disposal would 

36 ensure that all mitigation measures to minimize related potential impacts would be taken. 

37 Ordinary solid wastes would include trash, spent materials, and broken equipment. Hazardous 

38 waste would represent a very small volume of spent reagents and other items such as batteries. 

39 Radioactive solid waste would consist of Ross Project equipment, process vessels, building 

40 components, and other items that could not be decontaminated and released as nonradioactive. 

41 Although all of these wastes would be disposed of at offsite waste-disposal facilities, the 

42 relatively small volume of such wastes would have little impact on the respective disposal 

43 facilities’ ultimate capacity. Waste management impacts during all phases of the Ross Project 

44 would be SMALL. 
DRAFT Cost-Benefit Analysis

7-8

1 7.1.3 Findings and Conclusions

2

3 Implementation of the Proposed Action would have a SMALL to MODERATE socioeconomic 

4 impact on the ROI, with MODERATE impacts associated with the benefits of the additional tax 

5 revenue projected to accrue to Crook County. Regional benefits would include increased 

6 employment, economic activity, and tax revenues in the region and the State of Wyoming. 

7 Because the Applicant is committed to hiring locally, population increases and the subsequent 

8 need for additional public services is projected to be negligible. Access restrictions to the Ross 

9 Project area would result in the loss of some economic activities, but this loss is expected to be 

10 offset to a degree by the Applicant’s compensation to the affected landowners. A limited 

11 number of residents would also be affected by light pollution from the Ross Project. However, 

12 overall, the economic benefits of the Proposed Action would be greater than the associated 

13 costs.

14

15 7.2 Alternative 2: No Action

16

17 Under the No-Action Alternative, the NRC would not issue the Applicant a license to construct, 

18 operate, restore the aquifer, and decommission the proposed Ross Project. Area residents 

19 would benefit from some limited preconstruction activities, but no longer-term economic benefits 

20 would accrue to area residents, local jurisdictions, or the State. Similarly, there would be no 

21 potential costs borne by nearby jurisdictions and residents.

22

23 7.3 Alternative 3: North Ross Project

24

25 Construction, operation, aquifer restoration, and decommissioning of the North Ross Project are 

26 not expected to result in any significant differences in this cost-benefit analysis. Overall land 

27 use impacts would be generally the same as for the Proposed Action, although impacts to dry28 land crop agriculture would be lower, while impacts to grazing activities would be greater. Small 

29 changes in traffic patterns on roads to and in the Ross Project Area would result in reduced 

30 traffic volumes on New Haven Road that would be offset by increased traffic on other roads. 

31 These changing traffic patterns would slightly increase noise and air quality impacts, but the 

32 impacts would be offset by fewer affected residents. Impacts to other resources areas also are 

33 generally the same as for the Proposed Action. Thus, the major benefits and costs described 

34 for the Proposed Action would accrue similarly were the facility to be constructed and operated 

35 at the north site. 

36

37 7.4 References

38

39 (US)CB (U.S. Census Bureau, USDOC). “State and County QuickFacts, Wyoming, Crook 

40 County, Campbell County.” 2012. At http://quickfacts.census.gov/qfd/states/56000.html (as of 

41 June 25, 2012). 

42

43 (US)DA (U.S. Department of Agriculture). 2007 Census of Agriculture, County Profile, Crook 

44 County, Wyoming. Washington, DC: USDA. 2009. ADAMS Accession No. ML13014A730. 

45

46 Mitchell, David, Julie Gallaway, and Reed Olsen. “Estimating the Willingness to Pay for Dark 

Skies Draft)” In 83rd 47 Annual Meetings of the Western Economic Association International. 

48 Springfield, MO: Missouri State University. July 2008. ADAMS Accession No. ML13024A313. 
DRAFT Cost-Benefit Analysis

7-9

1

2 (US)NRC (U.S. Nuclear Regulatory Commission). Environmental Review Guidance for 

3 Licensing Actions Associated with NMSS Programs. NUREG–1748. Washington, DC: 

4 USNRC. August 2003. ADAMS Accession No. ML032450279. 

5

6 (US)NRC. Generic Environmental Impact Statement for In-Situ Leach Uranium Milling 

7 Facilities. Volumes 1 and 2. NUREG–1910. ML09148024 and ML0911480188. Washington, 

8 D.C.: NRC. 2009. 

9

10 Strata (Strata Energy, Inc.). Ross ISR Project USNRC License Application, Crook County, 

11 Wyoming, Technical Report, Volumes 1 through 6 with Appendices. Docket No. 40-09091. 

12 Gillette, WY: Strata. 2011a. Agencywide Documents Access and Management System 

13 (ADAMS) Accession Nos. ML110130333, ML110130335, ML110130314, ML110130316, 

14 ML110130320, and ML110130327. 

15

16 Strata. Ross ISR Project USNRC License Application, Crook County, Wyoming, Environmental 

17 Report, Volumes 1, 2 and 3 with Appendices. Docket No. 40-09091. Gillette, WY: Strata. 

18 2011b. ADAMS Accession Nos. ML110130342, ML110130344, and ML110130348. 

19 Strata. Ross ISR Project USNRC License Application, Crook County, Wyoming, RAI Question 

20 and Answer Responses, Environmental Report, Volume 1 with Appendices. Docket No. 40-

21 09091. Gillette, WY: Strata. 2012. ADAMS Accession No. ML121030465. 

22

23 Strata and Crook County. Memorandum of Understanding for Improvement and Maintenance of 

24 Crook County Roads Providing Access to the Ross ISR Project. Sundance, WY: Strata and 

25 Crook County. April 6, 2011. 

26

27 WLSO (Wyoming Legislative Service Office). Wyoming Severance Taxes and Federal Mineral 

28 Royalties. ML13015A700. Cheyenne, WY: WLSO. 2010. 

DRAFT Environmental Consequences

8-1

1 8 SUMMARY OF ENVIRONMENTAL CONSEQUENCES

2

3 The environmental consequences of the Proposed Action, the Ross Project, and Alternative 3, 

4 the North Ross Project, are summarized next in Table 8.1.
8-2

Table 8.1

Summary of Environmental Consequences of the Proposed Action and Alternatives

Unavoidable

Adverse 

Environmental 

Impacts

Irreversible and 

Irretrievable Commitment 

of Resources

Short-Term Impacts

and 

Uses of the Environment

an

LAND USE

Alternative 1:

Proposed Action

Ross Project

(See SEIS Section 4.2.1.)

There would be SMALL 

unavoidable adverse impacts on 

land use over the lifecycle of the 

Ross Project because certain areas 

of the Project area would be fenced 

during the Project’s construction, 

operation, aquifer restoration, and 

decommissioning. The area 

disturbed, however, is small—113 

hectares (ha) [280 acres (ac)]. At 

the end of the Project, after facility 

decommissioning and site 

restoration have been fully 

accomplished, the former land uses 

of the Ross Project area would be 

restored.

There would be no irreversible or 

irretrievable impacts to land use 

in the area as a result of the 

Proposed Action. All land would 

be restored to its baseline uses 

post-Ross Project. Access 

roads would be removed, or they 

would be left as desired by the 

respective landowner(s).

There would be short-term landuse impacts during the Proposed 

Action, predominantly due to a 

decrease in the total area 

available for livestock grazing.

The

imp

Ros

wou

lice

land 

afte

Pro

Alternative 3:

North Ross Project

(See SEIS Section 4.2.3.)

Approximately the same number of 

acres would be taken out from 

service during Alternative 3. The 

area that would be disturbed would 

still be small. However, some 

livestock grazing could be 

diminished during the lifecycle of 

Alternative 3. However, as above, 

after complete facility 

decommissioning and site 

restoration have been 

accomplished, the former land use 

would be restored.

There would be no irreversible or 

irretrievable impacts to land use 

in the area as a result of 

Alternative 3. All land would be 

restored to its baseline uses.

There would be short-term 

impacts to land use in 

Alternative 3. The total area 

available for livestock grazing 

would be temporarily reduced.

The

imp

are

the 

the 

wou

dec

Alte
8-3

Table 8.1

Summary of Environmental Consequences of the Proposed Action and Alternatives

Unavoidable

Adverse 

Environmental 

Impacts

Irreversible and 

Irretrievable Commitment 

of Resources

Short-Term Impacts

and 

Uses of the Environment

an

TRANSPORTATION

Alternative 1:

Proposed Action

Ross Project

(See SEIS Section 4.3.1.)

During the four phases of the 

Proposed Action, the unavoidable 

impacts to transportation, which 

would be related specifically to 

traffic volumes, would range from 

SMALL to LARGE. Because the 

Ross Project is located in a rural 

area of Wyoming, where traffic is 

sparse, the increase in traffic as a 

result of the Proposed Action could 

create SMALL to LARGE impacts. 

However, with the mitigation 

measures the Applicant has 

proposed, during all phases of the 

Ross Project, transportation 

impacts would be SMALL to 

MODERATE.

There would be no long-term 

irreversible or irretrievable 

environmental impacts from 

increases in transportation by 

the Proposed Action. Once the 

Ross Project has been 

decommissioned and the site 

restored, all traffic impacts of the 

Proposed Action would cease as 

all related traffic would be zero.

Transportation impacts to the 

vicinity of the Proposed Action 

would be SMALL to 

MODERATE, with mitigation. 

These impacts would include 

increased traffic counts and a 

slightly higher probability of 

vehicular accidents. All of these 

short-term impacts would cease 

after the decommissioning of the 

Ross Project.

The 

Pro

tran

be 

Dur

App

roa

Pro

ma

ma

pro

cea

is c

roa

bet

cur

Alternative 3:

North Ross Project

(See SEIS Section 4.3.3.)

The construction and operation of 

the Central Processing Plant (CPP) 

at the north site would, in general, 

have the same transportation 

impacts as the Proposed Action, 

and these impacts would be 

SMALL to LARGE. With mitigation 

measures, the impacts would be 

SMALL to MODERATE.

There would be no irreversible 

impacts to land use in the area 

as a result of Alternative 3. All 

transportation impacts would 

cease at the conclusion of 

Alternative 3. Access roads 

would be removed, or they 

would be left as desired by the 

respective landowner(s).

There would also be short-term 

impacts to transportation in 

Alternative 3, and they would be 

the same as for the Proposed 

Action. 

The 

Alte

as t

whe

by t

imp

afte

dec

res
8-4

Table 8.1

Summary of Environmental Consequences of the Proposed Action and Alternatives

Unavoidable

Adverse 

Environmental 

Impacts

Irreversible and 

Irretrievable Commitment 

of Resources

Short-Term Impacts

and 

Uses of the Environment

an

GEOLOGY AND SOILS

Alternative 1:

Proposed Action

Ross Project

(See SEIS Section 4.4.1.)

There would be SMALL 

unavoidable adverse potential 

environmental impacts to the 

geology and soils at the Proposed 

Action. Wind and water erosion 

are possible, but the Applicant

would mitigate the potential for 

erosion with best management 

practices (BMPs) specifically 

related to erosion. (Fugitive dust is 

discussed under “Air Quality” in this 

Table.) There would be few 

geology and soils impacts during 

the Proposed Action.

There would be no irreversible or 

irretrievable commitment of 

geology or soil resources during 

the Proposed Action. No 

permanent changes would occur 

to the overall geology and soils 

of the Ross Project.

There would be some short-term 

potential impacts to soils under 

the Proposed Action, such as 

loss due to erosion. With the 

mitigation measures proposed 

by the Applicant, however, these 

potential impacts are unlikely, 

even over the short term.

The

imp

dur

the 

Alternative 3:

North Ross Project

(See SEIS Section 4.4.3.)

Alternative 3, as in the Proposed 

Action, would have the potential for 

wind or water erosion. With 

mitigation, however, little erosion 

would be expected. Greater soil 

disturbance for construction of the 

surface impoundments for 

Alternative 3 would be expected 

because of the site-specific 

topographic conditions. There 

would be SMALL impacts to the 

geology and soils at the Ross 

Project area.

There would be no irreversible or 

irretrievable impacts to geology 

or soils during Alternative 3.

There would be small impacts 

related to the potential for 

eroding soils during Alternative 

3; these would be mitigated and, 

consequently, SMALL.

The

imp

Alte
8-5

Table 8.1

Summary of Environmental Consequences of the Proposed Action and Alternatives

Unavoidable

Adverse 

Environmental 

Impacts

Irreversible and 

Irretrievable Commitment 

of Resources

Short-Term Impacts

and 

Uses of the Environment

an

WATER RESOURCES: SURFACE WATER

Alternative 1:

Proposed Action

Ross Project

(See SEIS Section 4.5.1.)

There would be SMALL 

unavoidable adverse impacts on 

surface water over the lifecycle of 

the Ross Project. Surface water 

would be potentially impacted by 

sediment from stormwater run-off 

and crossing water features with 

roads and pipelines. The moisture 

conditions of wetlands situated 

along the Little Missouri River and 

adjacent to the Oshoto Reservoir 

would potentially be impacted. 

Accidental leaks, spills, and other 

releases of fluids would potentially 

impact surface water quality. With 

mitigation, however, little 

sedimentation would be expected 

and accidental releases would be 

contained. 

There would be no irreversible or 

irretrievable impacts to surface 

water by the Proposed Action. 

Small amounts of surface water 

would be used for construction 

activities and dust control, but 

this water would be replaced by 

normal precipitation.

There would be some short-term 

potential impacts to surface 

water under the Proposed 

Action, such as increased 

sedimentation. With the 

mitigation measures proposed 

by the Applicant, however, these 

potential impacts are unlikely, 

even over the short term.

The

imp

the 

Pro

Alternative 3:

North Ross Project

(See SEIS Section 4.5.1.)

The construction and operation of 

the CPP at the north site in 

Alternative 3 would, in general, 

have the same surface water 

impacts as the Proposed Action; 

however the mitigation measures

required to protect the two 

ephemeral drainages and the 

steeper land slopes at the North 

Ross Project would involve more 

engineering. With mitigation 

measures, the impacts would be 

SMALL.

As with the Proposed Action, 

there would be no irreversible or 

irretrievable impacts to surface 

water during Alternative 3.

The potential short-term impacts 

to surface water during 

Alternative 3 would be the same 

as for the Proposed Action.

The

imp

Nor

Alte
8-6

Table 8.1

Summary of Environmental Consequences of the Proposed Action and Alternatives

Unavoidable

Adverse 

Environmental 

Impacts

Irreversible and 

Irretrievable Commitment 

of Resources

Short-Term Impacts

and 

Uses of the Environment

an

WATER RESOURCES: GROUND WATER

Alternative 1:

Proposed Action

Ross Project

(See SEIS Section 4.5.1.)

There would be SMALL 

unavoidable adverse impacts to 

water quality and MODERATE 

unavoidable adverse impacts to 

water quantity on ground-water 

resources over the lifecycle of the 

Ross Project. Aquifers would be 

impacted by water withdrawal and 

injection of lixiviant. Lowering of 

water levels would be seen within 

and outside the Project area. The 

water quality of the aquifers outside 

and below the exempted aquifer 

would temporarily be impacted if 

excursions of lixiviant were to 

occur. Ground water above the 

exempted aquifer would potentially 

by impacted by leaks from wells 

and releases at the surface. With 

mitigation, however, little potential 

for excursions, leaks and 

accidental releases would be 

minimized. There would be SMALL 

to MODERATE impacts to the

ground water quantity and SMALL 

impacts to ground water quality at 

the Ross Project area.

There would be no irreversible or 

irretrievable impacts to ground 

water from the Proposed Action. 

The lower ground water levels in 

the ore-zone aquifer and the 

aquifer overlying the ore zone 

would be replaced by normal 

recharge over time. Excursions 

would be remediated by 

pumping out contaminated 

water. The water quality of the 

exempted aquifer would 

consequently be restored.

Lowering of water levels would 

be a short-term impact to ground 

water from the Proposed Action. 

Based upon historical 

experience with uraniumrecovery projects, excursions of 

lixiviant often occur and create 

short-term impacts to water 

quality. The mitigation 

measures proposed by the 

Applicant and required by permit 

and license conditions, such as 

water-management actions to 

minimize water usage from the 

aquifers, tests to ensure integrity 

of the wells, and early detection 

of excursions short-term impacts 

would reduce these impacts at 

the Ross Project.

The

imp

Pro

leve

nor

res

the 

res
8-7

Table 8.1

Summary of Environmental Consequences of the Proposed Action and Alternatives

Unavoidable

Adverse 

Environmental 

Impacts

Irreversible and 

Irretrievable Commitment 

of Resources

Short-Term Impacts

and 

Uses of the Environment

an

WATER RESOURCES: GROUND WATER (Continued)

Alternative 3:

North Ross Project

(See SEIS Section 4.5.3.)

The construction and operation of 

the CPP at the north site would 

have the same mitigated impacts to 

ground water as the Proposed 

Action except, during Alternative 3, 

fewer mitigation measures to 

minimize the potential impacts to 

the shallow, unconfined aquifer 

from spills and leaks of byproduct 

liquid waste from the 

impoundments would be required. 

The greater depth to the shallow 

aquifer below the impoundments at 

the north site would eliminate the 

need for the containment barrier 

wall to prevent ground-water flow in 

the area below the impoundments 

as in the Proposed Action. 

Mitigation of the potential for leaks 

from the impoundments at the 

north site would rely upon leak 

detection and monitoring systems 

as well as remediation if 

contaminants reached the ground 

water.

As described for the Proposed 

Action, there would be no 

irreversible or irretrievable 

impacts to ground water under 

Alternative 3.

The short-term impacts during 

Alternative 3 would be the same 

as described for the Proposed 

Action.

The

imp

Nor

Alte
8-8

Table 8.1

Summary of Environmental Consequences of the Proposed Action and Alternatives

Unavoidable

Adverse 

Environmental 

Impacts

Irreversible and 

Irretrievable Commitment 

of Resources

Short-Term Impacts

and 

Uses of the Environment

an

ECOLOGY 

Alternative 1:

Proposed Action

Ross Project

(See SEIS Section 4.6.1.)

There would be SMALL 

unavoidable impacts related to the 

ecology of the Proposed Action. 

Some wildlife could be displaced 

during Project activities, especially 

during construction and 

decommissioning. The areas 

where human activities would be 

conducted could interrupt wildlife, 

bird, and protected species that 

presently occur on the site. In 

addition, some vegetative impacts 

could occur as the land is used for 

uranium recovery. However, once 

facility decommissioning and site 

restoration have been completed 

all of these impacts would diminish, 

or baseline conditions would be reestablished, and the ecology of the 

Project area would be restored 

over time.

There would be no irreversible or 

irretrievable commitment of 

ecological resources during the 

Proposed Action. There are no 

Greater-sage-grouse leks on the 

Ross Project itself. If one or 

more were to become present, 

the Applicant would be required 

to alter its activities, as 

appropriate, at the Ross Project. 

There would be some short-term 

impacts to the ecology of the 

Proposed Action which would 

include the disruption of some 

species of vegetation as well as 

the potential for wildlife, 

including birds, to move 

elsewhere, away from Ross 

Project activities and noise. 

These impacts would cease 

when the decommissioning and 

reclamation of the Ross Project 

area are complete and the local 

habitat is restored.

The

imp

Pro

clos

wou

wou

Pro

bas

Alternative 3:

North Ross Project

(See SEIS Section 4.6.3.)

Alternative 3 would have the 

potential for the same impacts to 

the local ecology as the Proposed 

Action. These impacts, however, 

would be SMALL.

There would be no irreversible or 

irretrievable impacts to the local 

ecology during Alternative 3.

There would be small, short-term 

impacts related to the 

disturbance of native vegetation 

and nearby wildlife during 

Alternative 3; these would be 

SMALL and would be the same 

as the Proposed Action.

The

imp

Alte
8-9

Table 8.1

Summary of Environmental Consequences of the Proposed Action and Alternatives

Unavoidable

Adverse 

Environmental 

Impacts

Irreversible and 

Irretrievable Commitment 

of Resources

Short-Term Impacts

and 

Uses of the Environment

an

AIR QUALITY

Alternative 1:

Proposed Action

Ross Project

(See SEIS Section 4.7.1.)

There would be unavoidable 

adverse effects to local air quality 

due to the emission of combustion 

gases and fugitive dusts during all 

of the phases of the Proposed 

Action. These impacts would be 

SMALL. Fugitive dusts would 

become airborne during 

construction activities (e.g., road 

construction and site clearing and 

contouring) as well as during 

vehicular use to, from, and on the 

Project area. The Applicant would 

have an Air Quality Permit, 

however, that would require air 

emissions to be mitigated so that 

emissions would be kept to a 

minimum.

No permanent changes would 

occur to the overall quality of air 

at or near the Ross Project.

There would be SMALL shortterm potential impacts to air 

quality under the Proposed 

Action. Gaseous and fugitivedust emissions would be 

generated during all phases of 

the Ross Project. With the 

mitigation measures proposed 

by the Applicant, and those 

required by its Air Quality Permit, 

however, these potential impacts 

would be short term.

The

imp

Pro

Act

dec

are

air-

Alternative 3:

North Ross Project

(See SEIS Section 4.7.3.)

Under Alternative 3, the same airquality impacts would occur as 

during the Proposed Action. 

Because the CPP would be located 

such that gravel-road surfaces 

would be used slightly more often, 

there could be slightly more fugitive 

dust generated under Alternative 3.

No permanent changes would 

occur to the overall quality of air 

at or near the North Ross 

Project. 

As for the Proposed Action, 

Alternative 3 would generate 

gaseous and fugitive-dust 

emissions throughout its 

lifecycle. But these impacts 

would also be SMALL.

The

imp

of A

the 

dec

are

air-
8-10

Table 8.1

Summary of Environmental Consequences of the Proposed Action and Alternatives

Unavoidable

Adverse 

Environmental 

Impacts

Irreversible and 

Irretrievable Commitment 

of Resources

Short-Term Impacts

and 

Uses of the Environment

an

NOISE

Alternative 1:

Proposed Action

Ross Project

(See SEIS Section 4.8.1.)

There would be would be SMALL 

to MODERATE unavoidable 

adverse noise impacts during the 

Proposed Action. Because the 

Ross Project has several 

residences located near its 

boundaries, the noise generated 

during the Project’s lifecycle would 

be MODERATE to those nearest 

receptors. In addition, due to 

supply deliveries, commuter traffic, 

and shipments from the Project, 

there would be increased vehicular 

noise. The four phases of the 

south Ross Project facility, 

including the CPP, surface 

impoundments, and other 

structures as well as the installation 

of wells would cause noise impacts 

that could not entirely be mitigated 

for nearby residents; however, the 

noise impacts would quickly 

diminish at greater distances from 

the Ross Project area. 

There would be no long-term 

permanent noise impacts from 

the Proposed Action. Once the 

Ross Project has been 

decommissioned and the site 

restored, all Project-related 

noise would cease.

Short-term noise impacts in the 

vicinity of the Proposed Action 

would be SMALL to 

MODERATE. These impacts 

would include increased 

construction noise as well as 

increased vehicular noise. All 

such impacts, however, would 

cease after facility 

decommissioning and site 

restoration activities are 

complete.

The

imp

with 

Alternative 3:

North Ross Project

(See SEIS Section 4.8.3.)

During Alternative 3, there would 

be SMALL to MODERATE 

unavoidable adverse impacts with 

respect to noise. These impacts 

would be the same as in the 

Proposed Action, except some 

noise impacts would be diminished 

because construction and 

decommissioning activities at the 

north site would be a greater 

distance to the nearest residence.

There would be no long-term 

permanent noise impacts from 

Alternative 3. Once the north 

Ross Project has been 

decommissioned and the site 

restored, all Project-related 

noise would cease.

Short-term noise impacts in the 

vicinity of Alternative 3 would be 

SMALL to MODERATE. These 

impacts would include increased 

construction noise as well as 

increased vehicular noise. All 

such impacts, however, would 

cease after facility 

decommissioning and site 

restoration activities are 

complete.

The

imp

res
8-11

Table 8.1

Summary of Environmental Consequences of the Proposed Action and Alternatives

Unavoidable

Adverse 

Environmental 

Impacts

Irreversible and 

Irretrievable Commitment 

of Resources

Short-Term Impacts

and 

Uses of the Environment

an

HISTORICAL, CULTURAL, AND PALEONTOLOGICAL RESOURCES

Alternative 1:

Proposed Action

Ross Project

(See SEIS Section 4.9.1.)

Impacts on historic and cultural 

resources during the ISR 

construction phase would be 

SMALL to LARGE. To mitigate 

the impact, NRC, BLM, WY 

SHPO, Tribes, and the Applicant 

will develop and execute an 

agreement that would formalize 

treatment plans for adversely 

impacted resources during 

construction. If other NRHPeligible sites cannot be avoided 

then treatment plans would be 

developed. If other historic and 

cultural resources are 

encountered during the ISR 

lifecycle, the Applicant would 

notify the appropriate authorities 

per an unexpected discovery 

plan. 

If archaeological and historic 

sites cannot be avoided, or the 

impacts to these sites cannot be 

mitigated, this could result in an 

irreversible and irretrievable loss 

of cultural resources.

There would be a SMALL to 

LARGE impact on historic and 

cultural resources during the ISR 

construction phase. The 

development of an agreement 

between NRC, BLM, WY SHPO, 

Tribes, and the Applicant would 

address adverse impacts to 

cultural and historic sites and 

historic properties of traditional 

religious and cultural importance 

to Native American tribes. If any 

unidentified historic or cultural 

resources are encountered, work 

would stop and appropriate 

authorities would be notified per 

the unexpected discovery plan.

If po

imp

actio

long

histo

Alternative 3:

North Ross Project

(See SEIS Section 4.9.3.)
8-12

Table 8.1

Summary of Environmental Consequences of the Proposed Action and Alternatives

Unavoidable

Adverse 

Environmental 

Impacts

Irreversible and 

Irretrievable Commitment 

of Resources

Short-Term Impacts

and 

Uses of the Environment

an

VISUAL AND SCENIC RESOURCES

Alternative 1:

Proposed Action

Ross Project

(See SEIS Section 4.10.1.)

There would be SMALL 

unavoidable impacts related to the 

visual and scenic resources at the 

Proposed Action. During the 

construction and decommissioning 

phases, in particular, earthmovement activities could be seen 

by a few of the nearby residents, 

who could experience MODERATE 

impacts. The lights of the Project 

could also be seen by some of the 

nearest neighbors. There would be 

many mitigation measures related 

to the lights of the Ross Project 

which would be implemented by 

the Applicant to diminish as much 

as possible the light emanating 

from the Proposed Action. 

There would be no irreversible or 

irretrievable commitment of 

visual or scenic resources 

caused by the Proposed Action. 

All visual-resource impacts 

would be eliminated upon the 

Ross Project’s facility 

decommissioning and site 

restoration activities. These 

activities would include restoring 

the baseline contours of the 

Ross Project area.

There would be some short-term 

impacts to the visual resources 

at the Proposed Action. These 

would include changes to the 

topography of the area; the 

presence of man-made 

structures; and light during 

nighttime hours. These impacts 

would cease when the 

decommissioning and 

reclamation of the Ross Project 

area are complete, when the 

baseline topography is restored 

and all lights are removed.

The

imp

res

are

Pro

dec

imp

wou

the 

bas

Alternative 3:

North Ross Project

(See SEIS Section 4.10.3.)

Alternative 3 would have the 

potential for visual-resource 

impacts as the Proposed Action. 

These SMALL impacts would be 

even less than those of the Ross 

Project, because the natural 

topography of the north area would 

shield construction and operation 

activities related to the uraniumrecovery facility. Thus, the closest 

residences’ views would be less 

impacted as would their experience 

of light in the nighttime skies.

There would be no irreversible or 

irretrievable impacts to the visual 

and scenic resources caused by 

Alternative 3.

There would be small, short-term 

impacts related to the 

disturbance of native vegetation 

and nearby wildlife during 

Alternative 3; these would be 

SMALL and would be the same 

as the Proposed Action.

The

imp

3.
8-13

Table 8.1

Summary of Environmental Consequences of the Proposed Action and Alternatives

Unavoidable

Adverse 

Environmental 

Impacts

Irreversible and 

Irretrievable Commitment 

of Resources

Short-Term Impacts

and 

Uses of the Environment

an

SOCIOECONOMICS

Alternative 1:

Proposed Action

Ross Project

(See SEIS Section 4.11.1.)

There would be SMALL 

unavoidable impacts related to the 

socioeconomics at the Proposed 

Action. These impacts, however, 

would be related to the increased 

revenues that local jurisdictions 

would collect related taxes on the 

Ross Project. Other 

socioeconomic factors such as 

impacts to employment, income, 

demographics, housing, and 

education as well as demand for 

social and health services would be 

SMALL, while the impacts relate to 

local tax revenues would be 

MODERATE during the 

construction and operation phases 

of the Ross Project.

There would be no irreversible or 

irretrievable commitment of 

socioeconomic resources during 

the Proposed Action. 

Socioeconomic impacts would 

be diminished upon the Ross 

Project’s decommissioning. For 

example, the increased need for 

housing, although SMALL, would 

be eliminated after the Ross 

Project terminates. 

There would be some short-term 

impacts to socioeconomic 

resources by the Proposed 

Action. These would include 

SMALL to MODERATE potential 

changes to local employment, 

income, demographics, housing, 

and education as well as 

demand for social and health 

services. All tax payments 

would also be eliminated at the 

conclusion of the Ross Project.

The

imp

res

are

dec

tha

em

dem

edu

inte

wou

wis

and 

elim

pay

Alternative 3:

North Ross Project

(See SEIS Section 4.11.3.)

There would be the same SMALL 

to MODERATE socioeconomic 

impacts to the area surrounding 

Alternative 3. As the 

socioeconomic variables evaluated 

for this SEIS do not depend upon 

the geography of the Ross Project, 

the North Ross Project would 

accrue the same impacts as the 

Proposed Action.

There would be no irreversible or 

irretrievable commitment of 

socioeconomic resources during 

Alternative 3 as for the Proposed 

Action. 

There would be some short-term 

impacts to socioeconomic 

resources caused by Alternative 

3. These would include the 

same SMALL potential changes 

to local employment, income, 

demographics, housing, and 

education as well as demand for 

social and health services and 

MODERATE impacts to local 

jurisdictions. 

The

imp

res

Alte
8-14

Table 8.1

Summary of Environmental Consequences of the Proposed Action and Alternatives

Unavoidable

Adverse 

Environmental 

Impacts

Irreversible and 

Irretrievable Commitment 

of Resources

Short-Term Impacts

and 

Uses of the Environment

an

ENVIRONMENTAL JUSTICE

Alternative 1:

Proposed Action

Ross Project

(See SEIS Section 4.12.) There are no minority and low-income populations located within four miles of the Ros

Consequently, an environmental justice-analysis has not been performed for this Pro

Alternative 3:

North Ross Project

(See SEIS Section 4.12.)

PUBLIC AND OCCUPATIONAL HEALTH AND SAFETY

Alternative 1:

Proposed Action

Ross Project

(See SEIS Section 4.13.1.)

There would be a SMALL impact 

on public and occupational 

health. Construction and 

decommissioning would generate 

fugitive dust emissions that would 

not result in a significant dose to 

the public or site workers. The 

emissions from construction 

equipment would be of short 

duration and would readily 

disperse into the atmosphere.

Not applicable There would be a SMALL impact 

from radiological exposure. Dose 

calculations under normal 

operations showed that the highest 

potential dose within the proposed 

project area is 5 percent of the 1 

mSv [100 mrem] per year public 

dose limit specified in NRC 

regulations. The radiological 

impacts from accidents would be 

SMALL for workers if procedures to 

deal with accident scenarios are 

followed, and SMALL for the public 

because of the facility’s remote 

location. The nonradiological public 

and occupational health impacts 

from normal operations, accidents, 

and chemical exposures would be 

SMALL if handling procedures are 

followed.

The

to p

follo

Alternative 3:

North Ross Project

(See SEIS Section 4.13.3.)
8-15

Table 8.1

Summary of Environmental Consequences of the Proposed Action and Alternatives

Unavoidable

Adverse 

Environmental 

Impacts

Irreversible and 

Irretrievable Commitment 

of Resources

Short-Term Impacts

and 

Uses of the Environment

an

WASTE MANAGEMENT

Alternative 1:

Proposed Action

Ross Project

(See SEIS Section 4.14.1.)

There would be SMALL 

unavoidable adverse impacts as a 

result of waste management at the 

Proposed Action. The 

management of all waste streams 

(ordinary solid and domestic 

wastes, solid and liquid hazardous 

wastes, and all byproduct wastes) 

would be SMALL during all phases 

of the Ross Project. Many of the 

waste streams would be shipped 

off site to regulated (i.e., permitted 

or licensed as appropriate) 

facilities, which have undergone 

careful scrutiny by the respective 

regulatory agencies. In addition, 

discharge of small amounts of 

excess permeate into the Class I 

deep-injection wells at the Project 

would comply with Underground 

Injection Control (UIC) Permit from 

the Wyoming Department of 

Environmental Quality (WDEQ).

There would be no irreversible or 

irretrievable resources 

committed to waste 

management, except for the 

respective liquid wastes which 

would be injected into the 

Deadwood and Flathead 

Formations approximately 8,000 

feet below the surface. 

However, these aquifers are not 

potable and have not been 

identified as a source of oil and 

gas resources, the injection of 

waste would not impact the 

aquifer’s future use.

There would be few short-term 

impacts due to waste 

management at the Proposed 

Action. These short-term 

impacts, such as to 

transportation as well as public 

and occupational health and 

safety, which are described in 

those respective resource areas, 

would cease when waste is no 

longer generated or managed at 

the Ross Project. In addition, 

during the operation of the 

Proposed Action, there would be 

two double-lined surface 

impoundments over a 6.5 ha [16 

ac] area; the presence of these 

impoundments could have 

impacts to wildlife and birds. 

However, control features, such 

as an avian deterrent system 

would be operated throughout 

the Ross Project. These surface 

impoundments would be 

completely removed during 

facility decommissioning.

All R

eith

con

pha

the 

Dur

Act

stor

non

rep

imp

land 

Alternative 3:

North Ross Project

(See SEIS Section 4.14.3.)

There could be SMALL 

unavoidable waste-management 

impacts at Alternative 3. These 

would be the same as those 

indicated above for the Proposed 

Action. The volume of demolition 

waste could be somewhat less than 

the Proposed Action’s, because the 

containment barrier wall would not 

have been constructed.

This Alternative would also 

employ a deep-disposal well, so 

that the same commitment of the 

Deadwood and Flathead aquifer 

would occur.

The short-term impacts of 

Alternative 3’s management of 

wastes would be the same as 

those for the Proposed Action.

The 

Alte

was

tho

DRAFT List of Preparers

9-1

1 9 LIST OF PREPARERS

2

3 This section documents all individuals who were involved with the preparation of this Draft 

4 Supplemental Environmental Impact Statement (DSEIS). Contributors include staff from 

5 the NRC and its consultants. Each individual’s responsibilities and affiliation are as 

6 follows. 

7

8 9.1 U.S. Nuclear Regulatory Commission Contributors

9 Johari Moore: SEIS Project Manager

10 M.S., Nuclear Engineering and Radiological Science, University of Michigan, 2005

11 B.S., Physics, Florida A & M University, 2003

12 Years of Experience: 7

13 Ashley Waldron: SEIS Co-Project Manager

14 B.S., Biology, Frostburg State University, 2009

15 Years of Experience: 3

16

17 John Saxton: Safety Project Manager

18 Connecticut Licensed Environmental Professional, 2001

19 M.S., Geology, University of New Mexico, 1989

20 B.S., Geological Engineering, Colorado School of Mines, 1983

21 Years of Experience: 25

22

23 9.2 Attenuation Environmental Company Team

24 Doris Minor: Project Manager and Task Co-Manager

25 Attenuation Environmental Company

26 Radiological Public and Occupational Health and Safety/Solid and Radioactive Waste Management

27 B.A., English Literature, University of Washington, 1978

28 M.S.E., (Nuclear) Engineering, University of Washington, 1984

29 Years of Experience: 28

30

31 Dr. Kathryn Johnson: Assistant Project Manager and Task Co-Manager

32 Attenuation Environmental Company

33 Geochemistry/Geology/Water Resources/Liquid Waste Management/Facility Design and Operation

34 Ph.D., Geology, South Dakota School of Mines & Technology, 1986

35 M.S., Chemistry, Iowa State University, 1977

36 B.S., Chemistry and Mathematics, Black Hills State College, 1975

37

38 Jerry Boese

39 Ross & Associates Environmental Consulting Ltd., dba Ross Strategic 

40 Comment Responses

41 M.P.A., John F. Kennedy School of Government, Harvard University, 1989

42 B.S., Biology and Economics, Yale University, 1975

43 Years of Experience: 32
DRAFT List of Preparers

9-2

1 9.2 Attenuation Environmental Company Team

2 (Continued)

3 Dr. Tony Burgess

4 Attenuation Environmental Company 

5 Ground-Water Resources

6 Ph.D., Geology (Engineering Geology and Hydrogeology), 

7 University of Durham, United Kingdom, 1970

8 B.Sc., Geology University of Durham, United Kingdom, 1966

9 Years of Experience: 43

10

11 Dr. Cheryl Chapman, P.E.

12 RESPEC Consulting and Services Inc.

13 Tribal Coordination and Consultation

14 Ph.D. in Biological Sciences, South Dakota State University, 

15 Brookings, South Dakota, 2007

16 B.S., Civil and Environmental Engineering, 

17 South Dakota School of Mines & Technology, Rapid City, South Dakota, 1978 

18 B.S., Mathematics, South Dakota School of Mines & Technology, Rapid City, South Dakota, 1978 

19 Years of Experience: 32

20

21 Lauren Evans, P.E.

22 Pinyon Environmental Engineering Resources Inc. 

23 Land Use/Transportation/Ecological Resources/Meteorology

24 B.S., Geological Engineering, Colorado School of Mines, 1982

25 Years of Experience: 30

26 Linn Gould 

27 Erda Environmental Services Inc.

28 Environmental Justice/Cumulative Impacts

29 M.P.H., University of Washington, 2003

30 M.S., Soil Science, University of Wisconsin-Madison, 1988

31 B.A., Geology, Smith College, 1980

32 Years of Experience: 25

33

34 Dave Heffner, P.E. 

35 Aspect Consulting L.L.C.

36 Chemical Engineering

37 M.S., Chemical Engineering, Georgia Institute of Technology, 1981

38 B.S., Environmental Engineering, Rensselaer Polytechnic Institute, 1979

39 Years of Experience: 30

40

41 Mary Kenner

42 RESPEC Consulting and Services Inc.

43 Tribal Coordination and Consultation

44 B.S., Interdisciplinary Science, South Dakota School of Mines & Technology, 1998 

45 Years of Experience: 28
DRAFT List of Preparers

9-3

1 9.2 Attenuation Environmental Company Team

2 (Continued)

3 Scott Kindred, P.E. 

4 Aspect Consulting L.L.C.

5 Ground-Water and Surface-Water Resources/Geology/Soils

6 M.S., Civil Engineering, Massachusetts Institute of Technology, 1987

7 B.S., Geology, Brown University, 1983

8 Years of Experience: 20

9

10 Charles McClendon

11 The Delphi Groupe, Inc.

12 Radiological/Mining/Industrial Hygiene/RSO/NEPA

13 B.S., Civil (Mining) Engineering, Colorado School of Mines, 1976

14 M.B.A., Nova University, Dade County, Florida 1985

15 Years of Experience: 35

16

17 Dave McCormack

18 Aspect Consulting L.L.C.

19 Geology/Soils

20 M.S., Geology, Northern Arizona State University, 1989

21 B.S., Geological Sciences, University of Washington, 1983

22 Years of Experience: 23

23

24 Christian J. Miss

25 SWCA Environmental Consultants

26 Historical, Cultural, and Paleontological Resources/Tribal Consultation

27 B.A., Biology, Case Western Reserve University, 1970

28 M.A., Anthropology, Idaho State University, 1978

29 Years of Experience: 40

30

31 Jessie Piper 

32 SWCA Environmental Consultants

33 Historical, Cultural, and Paleontological Resources/Tribal Consultation

34 B.A., Anthropology, University of Arizona, 1989

35 M.A., Anthropology, University of Arizona, 1992

36 Years of Experience: 20

37

38 Debby Reber 

39 SWCA Environmental Consultants

40 Visual Resources 

41 B.A., Natural Resource Management, University of California, Chico, 1984

42 Years of Experience: 15
DRAFT List of Preparers

9-4

1 9.2 Attenuation Environmental Company Team

2 (Continued)

3 Owen Reese, P.E.

4 Aspect Consulting L.L.C.

5 Surface-Water Resources

6 M.S., Civil Engineering, University of Washington, 1997

7 B.S., Civil Engineering, University of Washington, 1996

8 Years of Experience: 15

9

10 Barbara Trenary

11 Attenuation Environmental Company

12 Air Quality/Noise/Non-Radiological Public and Occupational Health and Safety

13 B.S., Environmental Sciences, Industrial Hygiene, Colorado State University, 1979

14 Years of Experience: 33

15

16 Jeff Vitucci 

17 Robert D Niehaus Inc.

18 Socioeconomics/Cost-Benefit Analysis

19 M.A., Economics, University of California, Santa Barbara, 1978

20 B.A., Environmental Studies, San Jose State University, 1974

21 Years of Experience: 34

22

23 Elly Weber

24 Pinyon Environmental Engineering Resources Inc. 

25 Ecological Resources

26 M.S., Environmental Science, Texas Christian University, 2004

27 B.S., Biology, Texas Christian University, 2001

28 Years of Experience: 5

29

30 Richard Weinman

31 Attenuation Environmental Company: Assistant Project Manager

32 NEPA Analysis/Regulatory Compliance/Land Use Planning

33 B.A., English, New York University, 1965

34 M.A., English, Brandeis University, 1966

35 J.D., Law, University of Puget Sound (Seattle University) School of Law, 1978

36 Years of Experience: 33
DRAFT Distribution List

10-1

1 10 DISTRIBUTION LIST

2

3 The NRC is providing copies of this Draft Supplemental Environmental Impact Statement 

4 (DSEIS) to the organizations and individuals listed as follows. NRC will provide copies to other 

5 interested organizations and individuals upon request. 

6 10.1 Federal Agency Officials 

7

8 James Bashor 

9 Bureau of Land Management 

10 Newcastle Field Office

11 Newcastle, WY

12 John Keck

13 National Park Service

14 Devils Tower National Monument

15 Devils Tower, WY

16

17 Dr. John T Eddins

18 Advisory Council on Historic Preservation 

19 Washington, D.C.

20

21 10.2 Tribal Government Officials 

22

23 Donnie Cabniss

24 Apache Tribe

25 Tribal Historic Preservation Office

26 Anadarko, OK

27 John Murray

28 Blackfeet Tribe

29 Tribal Historic Preservation Office

30 Browning, MT 

31 Lynette Gray

32 Cheyenne and Arapaho Tribes

33 Tribal Historic Preservation Office

34 Concho, OK

35 Steve Vance

36 Cheyenne River Sioux Tribe

37 Tribal Historic Preservation Office

38 Eagle Butte, SD

39 Alvin Windy Boy, Sr.

40 Chippewa Cree Tribe

41 Tribal Historic Preservation Office

42 Box Elder, MT 
DRAFT Distribution List

10-2

1 Ira Matt

2 Confederated Salish & Kootenai Tribe

3 Tribal Historic Preservation Office

4 Pablo, MT 

5 Emerson Bull Chief

6 Crow Tribe

7 Tribal Historic Preservation Office

8 Crow Agency, MT

9 Wanda Wells

10 Crow Creek Sioux Tribe

11 Tribal Historic Preservation Office

12 Ft. Thompson, SD

13 Wilfred Ferris

14 Eastern Shoshone Tribe

15 Tribal Historic Preservation Office

16 Fort Washakie, WY 

17 James B. Weston

18 Flandreau-Santee Sioux Tribe

19 Tribal Historic Preservation Office

20 Flandreau, SD

21 Morris E. Belgard

22 Fort Belknap Tribe

23 Tribal Historic Preservation Office

24 Harlem, MT 

25 Darrell “Curley” Youpee

26 Fort Peck Tribes

27 Tribal Historic Preservation Office

28 Poplar, MT 

29 Amie Tah-bone

30 Kiowa Indian Tribe of Oklahoma

31 NAGPRA Representative

32 Carnegie, OK 

33 Clair S. Green

34 Lower Brule Sioux Tribe

35 Cultural Resources 

36 Lower Brule, SD 

37 Darlene Conrad

38 Tribal Historic Preservation Office

39 Northern Arapaho Tribe

40 Fort Washakie, WY 
DRAFT Distribution List

10-3

1 Conrad Fisher

2 Northern Cheyenne Tribe

3 Tribal Historic Preservation Office

4 Lame Deer, MT 

5 Richard Iron Cloud

6 Oglala Sioux Tribe

7 Tribal Historic Preservation Office

8 Pine Ridge, SD

9 Russell Eagle Bear

10 Rosebud Sioux Tribe

11 Tribal Historic Preservation Office

12 Rosebud, SD

13 Rick Thomas

14 Santee Sioux Tribe of Nebraska

15 Tribal Historic Preservation Office

16 Niobrara, NE 

17 Dianne Desrosiers

18 Sisseton-Wahpeton Oyate

19 Tribal Historic Preservation Office

20 Sisseton, SD

21 Darrell Smith

22 Spirit Lake Tribe

23 Tribal Historic Preservation Office

24 Fort Totten, ND 

25 Wašté Wiŋ Young

26 Standing Rock Sioux Tribe

27 Tribal Historic Preservation Office

28 Fort Yates, ND 

29 Elgin Crows Breast

30 Mandan, Hidatsa & Arikara Nation

31 Three Affiliated Tribes

32 Tribal Historic Preservation Office

33 New Town, ND 

34 Bruce F. Nadeau

35 Turtle Mountain Band of Chippewa

36 Tribal Historic Preservation Office

37 Belcourt, ND 

38 Lana Gravatt

39 Yankton Sioux Tribe

40 Tribal Historic Preservation Office

41 Wagner, SD 
DRAFT Distribution List

10-4

1 10.3 State Agency Officials 

2

3 Mary Hopkins 

4 Wyoming State Historic Preservation Office

5 Cheyenne, WY

6

7 Mark Rogaczewski

8 Wyoming Department of Environmental Quality

9 Land Quality Division

10

11 Tanner Shatto

12 Wyoming Department of Environmental Quality

13 Air Quality Division

14

15 John Passehl

16 Wyoming Department of Environmental Quality

17 Water Quality Division

18

19 Scott Talbott

20 Wyoming Game and Fish Department

21 Sheridan, WY

22

23 10.4 Local Agency Officials 

24

25 Crook County Commissioners

26 Sundance, WY

27

28 10.5 Other Organizations and Individuals

29

30 Shannon Anderson, Esq.

31 Powder River Basin Resource Council

32 Sheridan, WY

33

34 Geoffrey H. Fettus, Esq.

35 Natural Resources Defense Council

36 Washington, DC

37

38 Ralph Knode

39 Strata Energy, Inc,

40 Gillette, WY

41

42 Anthony Thompson, Esq.

43 Thompson & Pugsley, PLLC

44 Washington, DC

45

46 Echo Bohl

47 Crook County Library Hulett Branch

48 Hulett, WY
DRAFT Distribution List

10-5

1

2 Pamela Jespersen

3 Crook County Library Moorcroft Branch

4 Moorcroft, WY

APPENDIX A

CONSULTATION CORRESPONDENCE

Appendix A 

DRAFT Consultation Correspondence

A-1

1 CONSULTATION CORRESPONDENCE

2

3 The Endangered Species Act of 1973, as amended, and the National Historic Preservation Act 

4 of 1966, as amended, require that Federal agencies consult with applicable State and Federal 

5 agencies and groups prior to taking action that may affect threatened and endangered species, 

6 essential fish habitat, or historical and archaeological resources. This appendix lists 

7 consultation documentation related to these federal acts.

8

9

Table A.1 

Chronology of Consultation Correspondence

Author Recipient Date of Letter

ADAMS

Accession

Number

U.S. Nuclear 

Regulatory 

Commission 

(L. Camper)

Fort Peck Tribal 

Executive Board November 19, 2010* ML103160580

U.S. Nuclear 

Regulatory 

Commission 

(L. Camper)

Fort Belknap 

Community Council February 9, 2011** ML110400321

Turtle Mountain Band 

of Chippewa Indians 

(K. Ferris)

U.S. Nuclear 

Regulatory 

Commission 

(A. Bjornsen) April 14, 2011 ML111080059

U.S. Nuclear 

Regulatory 

Commission 

(K. Hsueh)

Sisseton-Wahpeton 

Lakota THPO (D. 

Desrosiers) August 11, 2011*** ML112220386

U.S. Nuclear 

Regulatory 

Commission 

(K. Hsueh)

U.S. Department of 

the Interior, Fish and 

Wildlife Service 

(M. Sattelberg) August 12, 2011 ML112200151

Apache Tribe of 

Oklahoma (L. Guy)

U.S. Nuclear 

Regulatory 

Commission

(A. Bjornsen) August 19, 2011 ML11336A224

U.S. Nuclear 

Regulatory 

Commission 

(A. Persinko)

Wyoming State 

Historic Preservation 

Office (M. Hopkins) August 19, 2011 ML112150393

U.S. Nuclear 

Regulatory 

Commission 

(A. Persinko)

Advisory Council on 

Historic Preservation 

(J. Fowler) August 19, 2011 ML112150427
Appendix A 

DRAFT Consultation Correspondence

A-2

Table A.1 

Chronology of Consultation Correspondence (Cont.)

Author Recipient Date of Letter

ADAMS

Accession

Number

U.S. Department of the 

Interior, Fish and 

Wildlife Service 

(M. Sattelberg)

U.S. Nuclear 

Regulatory 

Commission 

(K. Hsueh) September 13, 2011 ML112770035

Advisory Council on 

Historic Preservation 

(C. Hall)

U.S. Nuclear 

Regulatory 

Commission 

(A. Persinko) September 13, 2011 ML112770035

Wyoming Game and 

Fish Department (J. 

Emmerich)

U.S. Nuclear 

Regulatory 

Commission

(A. Bjornsen) September 22, 2011 ML112660130

U.S. Nuclear 

Regulatory 

Commission 

(L. Camper)

National Park 

Service, Devils 

Tower National 

Monument (D. 

FireCloud) December 5, 2011 ML113120356

U.S. Nuclear 

Regulatory 

Commission 

(K. Hsueh)

Strata Energy, Inc. 

(M. James) December 6, 2011 ML113200121

Advisory Council on 

Historic Preservation

(C. Vaughn)

U.S. Nuclear 

Regulatory 

Commission 

(A. Persinko) December 12, 2011 ML113480465

U.S. Nuclear 

Regulatory 

Commission 

(K. Hsueh)

Fort Peck Tribe 

(D. Youpee) December 22, 2011*** ML113420504

Strata Energy, Inc. 

(M. James)

U.S. Nuclear 

Regulatory 

Commission 

(K. Hsueh) January 12, 2012 ML120720266

U.S. Nuclear 

Regulatory 

Commission 

(K. Hsueh)

Advisory Council on 

Historic Preservation

(C. Vaughn) January 31, 2012 ML113490371

Rosebud Sioux Tribe 

(R. Eagle Bear)

U.S. Nuclear 

Regulatory 

Commission 

(A. Bjornsen) February 1, 2012 ML120390551
Appendix A 

DRAFT Consultation Correspondence

A-3

Table A.1 

Chronology of Consultation Correspondence (Cont.)

Author Recipient Date of Letter

ADAMS

Accession

Number

Strata Energy, Inc. 

(R. Knode)

U.S. Nuclear 

Regulatory 

Commission 

(K. Hsueh) August 31, 2012 ML12248A421

U.S. Nuclear 

Regulatory 

Commission 

(K. Hsueh)

Santee Sioux Tribe 

of Nebraska 

(R. Thomas) September 20, 2012*** ML12264A220

WWC Engineering 

(B. Schiffer)

U.S. Nuclear 

Regulatory 

Commission 

(J. Moore) October 16, 2012 ML12311A338

U.S. Nuclear 

Regulatory 

Commission

(K. Hsueh)

Kiowa Indian Tribe 

(J. Eskew) November 21, 2012*** ML12325A776

1 *Similar letters sent to Cheyenne River Sioux Tribe (J. Plenty), Crow Creek Sioux Tribe (L. Thompson, Jr.), Lower Brule Sioux Tribal 

2 Council (M. Jandreau), Oglala Sioux Tribal Council (T. Two Bulls), Rosebud Sioux Tribal Council (R. Bordeaux), Santee Sioux

3 Nation (R. Trudell), Standing Rock Sioux Tribe (R. Thunder), Three Affiliated Tribes Business Council (M. Wells), Northern 

4 Cheyenne Tribe (L. Spaug), Cheyenne and Arapaho Tribes (D. Flyingman), Arapaho Business Committee (H. Spoonhunter), Crow 

5 Tribal Council (C. Eagle), and Eastern Shoshone Tribe (I. Posey).

6

7 **Similar letters sent to Standing Rock Lakota Tribal Council (C. Murphy), Crow Tribal Council (C. Eagle), Apache Tribe of 

8 Oklahoma (H. Kostzuta), Sisseton-Wahpeton Lakota (A. Grey, Sr.), Yankton Lakota Tribe (R. Courneyor), Blackfeet Tribal Business 

9 Council (W. Sharp), Crow Creek Sioux Tribal Council (B. Sazue), Lower Brule Sioux Tribal Council (M. Jandreau), Spirit lake Tribal 

10 Council (M. Pearson), Oglala Lakota Tribal Council (T. TwoBulls), Shoshone Business Council (I. Posey), Northern Cheyenne Tribal 

11 Council (G. Small), Rosebud Sioux Tribal Council (R. Bordeaux), Fort Peck Tribal Executive Board (A. Stafne), Cheyenne and 

12 Arapahoe Tribes of Oklahoma (J. Boswell),Turtle Mountain Chippewa Tribal Council (R. Marcellias), Santee Sioux Nation (R. 

13 Trudell), Arapaho Business Council (H. Spoonhunter), Three Affiliated Tribes Business Council (M. Levings), Kiowa Indian Tribe of 

14 Oklahoma (D. Tofpi), Flandreau Santee Lakota Executive Committee (G. Bouland), Confederated Salish & Kootenai (E. Moran), and 

15 Cheyenne River Lakota Tribal Council (J. Plenty).

16

17 ***Similar letters sent to the Tribal Historic Preservation Officers: Fort Peck Tribal Executive Board (D. Youpee), Fort Belknap 

18 Community Council (D. Belgard), Standing Rock Lakota Tribal Council (W. Young), Crow Tribal Council (D. Old Horn), Yankton 

19 Lakota Tribe (L. Gravatt), Blackfeet Tribal Business Council (J. Murray), Crow Creek Sioux Tribal Council (W. Wells), Lower Brule 

20 Sioux Tribal Council (C. Green), Spirit lake Tribal Council (A. Shaw), Oglala Lakota Tribal Council (W. Mesteth), Shoshone Business 

21 Council (W. Ferris), Northern Cheyenne Tribal Council (C. Fisher), Rosebud Sioux Tribal Council (R. Eagle Bear), Cheyenne and 

22 Arapahoe Tribes of Oklahoma (D. Hamilton and), Santee Sioux Nation (L. Ickes), Arapaho Business Council (D. Conrad), Three 

23 Affiliated Tribes Business Council (E. Crows Breast), Kiowa Indian Tribe of Oklahoma (J. Eskew), Flandreau Santee Lakota 

24 Executive Committee (J. Weston), Confederated Salish & Kootenai (C. Burke), and Cheyenne River Lakota Tribal Council (S. 

25 Vance), Sisseton-Wahpeton Lakots (D. Desrosiers).

APPENDIX B

VISUAL IMPACTS ANALYSIS

Appendix B

DRAFT Visual Impacts Analysis

B-1

1 APPENDIX B: VISUAL IMPACT ANALYSIS

2

3 Scenic Quality Inventory Point B-1

4

5 Photograph from Scenic Quality Inventory Point C-1 to North

6

7

Table B.1

Scenic Quality Inventory and Evaluation

Key Factor Rating Criteria Score

Landform Low rolling hills, foothills, or flat valley bottoms or 

few or no interesting landscape features.

1

Vegetation Some variety of vegetation, but only one or two 

major types.

3

Water Present/Little Missouri River and the Oshoto 

Reservoir are occasionally visible.

1

Color

Some intensity or variety in colors and contrast of

the soil, rock, and vegetation, but not a dominant 

scenic element.

3

Influence of

Adjacent Scenery

Adjacent scenery has little or no influence on 

overall visual quality.

0

Scarcity Interesting within its setting, but fairly common 

within the region.

1

Cultural

Modifications

Modifications add variety, but are very discordant 

and promote strong disharmony.

-2

TOTAL SCORE 7

8

9
Appendix B

DRAFT Visual Impacts Analysis

B-2

1 Scenic Quality Inventory Point B-2

2

3 Photograph from Scenic Quality Inventory Point B-2 to East

4

5

Table B.2

Scenic Quality Inventory and Evaluation

Key Factor Rating Criteria Score

Landform

High vertical relief as expressed in prominent cliffs,

spires, or massive rock outcrops, or severe surface 

variation or highly eroded formations including 

major badlands or dune systems; or detail features

dominant and exceptionally striking and intriguing

such as glaciers.

5

Vegetation A variety of vegetative types as expressed in 

interesting forms, textures, and patterns.

5

Water Present, but not noticeable. 0

Color

Some intensity or variety in colors and contrast of 

the soil, rock, and vegetation, but not a dominant 

scenic element.

3

Influence of

Adjacent Scenery

Adjacent scenery greatly enhances visual quality

(Devils Tower).

5

Scarcity

One of a kind, or unusually memorable, or very rare

within region. Consistent chance for exceptional 

wildlife or wildflower viewing.

5

Cultural

Modifications

Modifications add little or no visual variety to the 

area, and introduce no discordant elements.

0

TOTAL SCORE 23
Appendix B

DRAFT Visual Impacts Analysis

B-3

1 Scenic Quality Inventory Point B-3

2

3 Photograph from Scenic Quality Inventory Point B-3 to South

4

5

Table B.3

Scenic Quality Inventory and Evaluation

Key Factor Rating Criteria Score

Landform Low rolling hills, foothills, or flat valley bottoms; or 

few or no interesting landscape features.

1

Vegetation Little or no variety or contrast in vegetation. 1

Water Present, but not noticeable. 0

Color Subtle color variations, contrast, or interest; 

generally mute tones.

1

Influence of

Adjacent Scenery

Adjacent scenery has little or no influence on 

overall visual quality.

0

Scarcity Interesting within its setting, but fairly common 

within the region.

1

Cultural

Modifications

Modifications add little or no visual variety to the 

area and introduce no discordant elements.

0

TOTAL SCORE 4

6
Appendix B

DRAFT Visual Impacts Analysis

B-4

1 Scenic Quality Inventory Point B-4

2

3 Photograph from Scenic Quality Inventory Point B-4 to South

4

5

6

Table B.4

Scenic Quality Inventory and Evaluation

Key Factor Rating Criteria Score

Landform Low rolling hills, foothills, or flat valley bottoms; or 

few or no interesting landscape features.

1

Vegetation Some variety of vegetation, but only one or two 

major types.

3

Water Present, but not noticeable. 1

Color

Some intensity or variety in colors and contrast of

the soil, rock and vegetation, but not a dominant 

scenic element.

3

Influence of

Adjacent Scenery

Adjacent scenery has little or no influence on 

overall visual quality.

0

Scarcity Interesting within its setting, but fairly common 

within the region.

1

Cultural

Modifications

Modifications add variety but are discordant and 

promote disharmony.

-1

TOTAL SCORE 8

7
Appendix B

DRAFT Visual Impacts Analysis

B-5

1

2

Table B.5

Scenic Quality Inventory and Evaluation

Average of Four Views

Key Factor Score

Landform 2.00

Vegetation 3.00

Water 0.50

Color 2.50

Influence of

Adjacent Scenery

1.25

Scarcity 2.00

Cultural

Modifications

-0.75

AVERAGE 10.50

3




UNITED STATES 

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

--------------------

OFFICIAL BUSINESS
NUREG

-1910

Draft

Supplement 5

Environmental Impact Statement for the Ross ISR Project 

in Crook County, Wyoming