public submissil8n 3 lk0-8rlv-lqg4 september 06, 2016 · page 1of1 as of: 8/31/16 2:39 pm received:...

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As of: 8/31/16 2:39 PM Received: August 29, 2016 Status: Pending_Post PUBLIC SUBMISSIL8N 3 ! PM 2: 54 Tracking No. lk0-8rlv-lqg4 Comments Due: September 06, 2016 Submission Type: Web

Docket: NRC-2013-0164 · License Application Request to Construct and.Operate the Reno Creek ISR Project

Comment On: NRC-2013-0164-0005 Reno Creek in Situ Uranium Recovery Project in Campbell County, Wyoming; Draft Supplement51l Environmental Impact Statement; Extension of Comment Period

Document: NRC-2013-0164-DRAFT-0003 Comment on FR Doc # 2016-17329

Submitter Information

Name: AUC LLC Address:

1536 Cole Blvd, Suite 230 Lakewood, CO, 80401

Email: [email protected]

General Comment

See attached PDF for AUC LLC's DSEIS comments.

DSEIS Comments 08292016

SUNSI Review Complete Template = ADM - 013

Attachments

E-RIDS= ADM -03 /,. ~

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https ://www .fdms.gov/f dms/ getcontent?o bj ectid=09000064821ab1 cO&forma:t=xml&showorig=false 08/31/2016

The Reno Creek JSR Project

Docket ID NRC-2013-0164

Cindy Bladey Chief, Rules, Announcements, and Directives Branch Office of Administration Mail Stop: OWFN-12-HOS U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

August 29,2016

Subject: Reno Creek In-Situ Uranium Recovery (ISR) Project, Supplement to the Generic Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities, Campbell County, Wyoming

Dear Ms. Bladey:

AUC LLC has reviewed the Draft Supplement Environmental Impact Statement (DSEIS) for the Reno Creek In-Situ Leach Recovery (ISR) Project. The following comments focus on suggested· corrections to improve the accuracy of the DSEIS. Comments are organized by section, page number, and line number.

AUC appreciates the opportunity to comment on the DSEIS and looks forward to the development of the final draft. Should you have questions regarding AUC's comments, please do not hesitate to contact me at your convenience.

Respectfully Submitted, '~

\ \ .. rr'1(A¥3~-12l"-·-·--·, .... .,_/

James H. Viellenave

President AUCLLC

1536 Cole Blvd. Suite 230 Lakewood CO, 80401

Ph. 303-953-7975 Fx. 303-953-7994

CMTl

Executive Summary; Page xx; Line 21

Wellfield disturbance is included in the "Total Disturbance Area for Removal of Vegetation and Topsoil" disturbance calculation in Table 1-3: Disturbance Calculations (AUC LLC. 2012a). For clarification, the following revision is suggested:

"The applicant estimated that the land swface area that would be C{ffected by proposed JSR

operations would be approximately 62 ha [154 ac]."

CMT2

Executive Summary; Page xxii; Line 20

The estimated disturbance for wellfield development is 134. 8 acres. The estimated 461 acres refers

to controlled lands for wellfields, not disturbance. Wellfield disturbance is included in the "Total Disturbance Area for Removal of Vegetation and Topsoil" disturbance calculation in Table 1-3: Disturbance Calculations (AUC LLC. 2012a). For clarification, the following revision is suggested:

"Wei/fields would be sequentially developed resulting in the disturbance of approximateZv 55 ha

[135 ac}."

CMT3

Executive Summary; Page xxvi;,Line 19-21

Deep disposal wells are permitted under WDEQ Class I UIC permit 09-621, and no treatment is

requirement. For clarification, the following revision is suggested:

Delete: " ... The NRC would require the liquid waste pumped into Class I deep disposal wells to be treated and monitored to verify-it meets the NRC release standards in 10 CFR Part 20, Subparts D and K."

Add. 11 •• .A UC has obtained a Class I UIC permit through WDEQ and has obtained a conditional

aquifer exemption of the permitted discharge zones .fi-0111 EPA pending the collection of water

quality data ji-0111 the permitted discharge zones. 11

CMT4

Executive Summary; Page xxiii; Line 42;_43

For clarification, the following revision is suggested:

August 2016 Page 1 of26

Amend, as follows " .... NRC staff acknowledge the possibility that impacts to air quality from foreseeable future actions could be as much as LARGE, to which the proposed Reno Creek JSR Pr~ject will contribute only SMALL potential impacts. "

CMT5

Executive Summary; Page xxxii; Line 44-45

SeeCMT 3.

CMT6

Section 1.2; Page 1-1; Line 28-29


Amend as follows" ... either grant, grant with conditions, or deny .... "

CMT7

Section 1.6; Page 1-8; Line'18

When mentioning AEA for the first time it is important to note that it is the AEA "as amended by UMTRCA" because there was no lle.(2) prior to UMTRCA. For clarification, the following revision is suggested:

"The NRC has statutory authority through the AEA, as amended by the Uranium Mill Tailings Radiation Control Act (UMTRCA), to regulate uranium ISR facilities."

CMT8

Section 2.1.1.1.1; Page 2-2; Line 28

SeeCMT 1.

CMT9


SeeCMT 1.


CMTlO

Section 2.1.1.J.2; Page 2-7; Line 9-10

The DEIS text gives a slightly different meaning than the text included in the ER. Reference ER Section 1.4 Central Processing Plant, Chemical Storage Facilities, Equipment Used, and Materials Processed, page 1-17 (AUC LLC. 2012a). For clarification, the following revision is suggested:

"Tanks at the main plant would contain various liquids, including barren lixiviant, barren eluant, yellowcake precipitation, washing, dewatering, process chemicals, and yellowcake slurry."

CMTll


The estimated mineable resource has been misstated. The following revision is suggested:

'The estimated mineable resource within the proposed project area is 7.12 million kilograms (kg) [15. 7 million pounds (lb)} ofU308 (yellowcake) with an average grade of 0.065 percent 5 (AUC, 2012a)"

CMT12

Section 2.1.1.1.2; Page 2-12; Line 9-11

The SERP will not review the pilot logs of wells. AUC geologists will review the pilot hole logs to determine if a well should be installed. The SERP will review the final W ellfield Hydrologic Data Package after the wellfield installation is completed. (Reference ER Section 7.2.2, Wellfield Hydrogeologic Data Packages [AUC LLC. 2012a] and TR Section 5.2.5 Safety and Environmental

Review Panel for SERP responsibilities [AUC LLC. 2012b]). The following revision is suggested:

Delete the following text: "Prior to installation of well casing, geophysical logs of all pilot holes would be reviewed by the SERP (see the section on Wellfield Hydrogeologic Data Packages)".

CMT13


The Class III aquifer exemption has been granted. To clarify, the following revision is suggested:

"The Class Ill aqu!fer exemption has been approved and is in place. the defined aquifer or its

portion are no longer protected as a USDW under the SDWA."


CMT14


Remove "delineation drilling results and" since AUC is not required nor did AUC make a commitment to provide delineation drilling results as part of the Hydrogeologic Data Package. Reference TR Section 5.2.5 Safety and Environmental Review Panel for SERP responsibilities (AUC LLC. 2012b). The following revision is suggested:

"The applicant's pumping test data will be included in wel(field hydrogeologic data packages,

which would be submitted.for review and evaluation by the SERP. "

CMT15


Monitor wells have been specifically excluded from 5-year MITs. Reference Action Items Public Meeting October 8, 2015 (ML15296A541), Draft LC 10.5 Response. For clarification, the following revision is suggested:

"To ensure the continued integrity of the wellfields, the applicant would test the mechanical integrity of all active iT~jection and production wells at least once every 5 years or after any rework that may need to be performed on the well."

CMT16


The Class I disposal well permit has been approved by the WDEQ/LQD. For clarification, the following revision is suggested: Replace sentence with:

"The Class I disposal well permit has been approved and the applicable requirements are

described in drqft SEIS Section 2.1. 1. 1. 6. "

CMT17


AUC suggests rewording to indicate both Teckla and Teapot are Cretaceous-age. For clarification, the following revision is suggested:

Delete: 11 ••• Lewis Formation and Cretaceous Teapot. .. 11

Add: " ... the Cretaceous-age Tedda Sandstone Member of the Lewis Formation and Teapot

Sandstone of .. 11


CMT18


AUC suggests rewording to indicate depths refer to discharge zones, not actual well depths. For clarification, the following revision is suggested:

Delete: " ... The permitted Class I deep disposal wells vary in depths between 2,130 and 2,400 m ... "

Add: " ... The permitted Class I discharge zones are located at depths betvveen approximate~y 2, 130

and 2,4001n ... "

CMT19


AUC has not included a resin-transfer truck in its operation procedures. Reference TR Section 3.2.1.2 Elution Circuit (AUC LLC. 2012b). The following revision is suggested:

Delete: "Next, the resin would be transferred to a resin-transfer truck which would have one or more compartments."

CMT20


There is no underlying aquifer within the proposed project area; therefore, AUC will not install underlying monitor wells. Reference TR Section 2.7.2.3 Hydrostratigraphic Units; Underlying Unit (AUC LLC. 2012b). For clarification, the following revision is suggested:

"Before beginning wellfield operations, the applicant must determine background water quality by sampling and analyzing water quality indicator constituents in the mineralized zone(s) and underlying and overlying aquifers where present across each wellfield (AUC, 2012b)."

CMT21


For excursion clarification, the following revision is suggested:

"An excursion at a monitoring 1vell is declared when the concentrations of certain indicator

parameters exceed upper control limits established by the license and verified by the State and

NRC. The pwpose of the monitoring well ring is to ensure that groundwater quality in aqu(fers

outside exempted zones is not impacted by !SR operations. Background water quality samples obtained from monitoring wells placed in the ore-bearing aquifers, as well as the underlying and


overlying aquifers (where present), would be used to define excursion parameters and UCLs. UCLs must be established before ISR operations begin because they are used to control and manage any excursions that may occur during the ISR operations and restoration phases. Groundwater monitoring for selected constituents, throughout the life of the proposed project, is discussed in draft SEIS Sections 7.2.5 and 7.3.4."

CMT22


There is no underlying aquifer within the proposed project area; therefore, AUC will not install underlying monitor wells (See CMT 24). The following revision is suggested:

"The applicant's restoration monitoring program.for the proposed project would include taking

samples fi·om monitoring wells and overlying aqu[fer wells eve1y 60 days during the restoration

phase o.f operations (AUC, 2012b)."

CMT23



"The restoration target monitoring well samples would be analyzed to determine whether water

quality has been restored, consistent with 10 CFR Part 40, Appendix A, Criterion 5B(5)".

CMT24


AUC did not commit to using pressure transducers in the perimeter monitoring wells. The following revision is suggested:

Delete: "Water levels in the perimeter monitoring wells would be measured continuously using pressure transducers to confirm hydraulic wellfield control".

CMT25


SeeCMT17.


CMT26


SeeCMT 18.

CMT27


Per Regulatory Guide 4.14, AUC provided the NRC with preoperational radiological sampling results for livestock adjacent to the proposed CPP location. Based on the nominal concentrations of NRC regulated constituents, the estimated dose to an individual from this pathway would be less than 5 percent of the applicable radiation protection standard (AUC 2012a). Thus, it was determined that additional sampling is not required nor was a commitment made to monitor livestock. For clarification, the following revision is suggested:

"The applicant has committed to monitoring air particulate, radon, sw.face soil, sediment, vegetation, sw.face water, and groundwater to ident[fY the presence o.fNRC- and WDEQ-regulated constituents. "

CMT28

Section 3.1; Page 3-1; Line 12

See CMT 1.

CMT29

Section 3.4.1.2; Page 3-18; Line 20

The thickness of the UA Aquifer is misstated, the range should be 300 to 400 ft. thick (reference TR Section 2.7.2.3 Hydrostratigraphic Units; UA Aquitard [AUC LLC. 2012b]). The following revision is suggested:

"The UA is approximately 91to122 m [300 to 400.ft} thick and consists of laterally continuous silt and clay-rich mudstones."

CMT30

Section 3.4.1.2; Page 3-21; Line 17-18

The depths indicated for the Teapot Formation are incorrect. It appears the text was revised to provide a range of estimated depths for both permitted discharge zones. The most recent WDEQ


UIC permit determination should be used as a reference for this information. For clarification, the following revision is suggested:

Delete: 11 ·:.The Teapot Sandstone Member is approximately 2,270 to 2,557 m [7,450 to 8,390 ft] below ground surface in the proposed project area (AUC, 2012c). 11

Add: 11 ••• The Tedda and Teapot Sandstones are located at depths between approximately 2, 130

and 2,400 111 [7,000 to 7,860 ft} below ground sw.face in the proposed project area (WDEQ, 2015).,,

CMT31


The groundwater flow is incorrectly stated a~ southeast. The following revision is suggested:

"Based on potentiometric maps, the applicant observed a general northward regional groundwater flow in the Lance and Fox Hills aquifer system with a groundwater divide in southeastern Campbell County and subsequent groundwater flow toward the northeast (AVC, 2012a).

CMT32


Vertical conductivities refer to the fine-grained confining units present in these formations that would impede vertical movement of water. The following revision is suggested:

Add: " ... cites the low vertical hydraulic conductivities {~ 10-8 cm/s [3.9 x 10-9 in/s}} of the fine

grained shale and mudstones intervals as a reason ... 11

CMT33


Madison and Minnelusa groundwater usage is located along the eastern flank of the PRB, at much shallower depths. The following revision is suggested:

"The Madison Limestone is a source of water for municipal water supply as well as industrial, irrigation, and stock water use in the easternmost Wyoming PRB. The City of Gillette uses the aquifer for its water supply. The Minnelusa Formation is also a major aquifer in the easternmost

Wyoming PRB."


CMT34


Clarification of aquifer definition. Initial or ephemeral water in a well that can be measured may not be of sufficient volume for sampling. The following revision is suggested:

"The SM Unit can be considered the uppermost aquifer, if at any specific location, the SM Unit or similar shallow sandstone unit, contains sufficient groundwater."

CMT35

Section 3. 5.2.3; Page 3-44; Line 29

The statement is correct, but "unsaturated" conditions is not accurate. The following revision is suggested:

"The aqu~fer conditions change ji-om saturated conditions in the western portion of the proposed project area to partially saturated conditions in the eastern portion (~30 percent in area) of the

proposed project area (A UC, 2012i)."

CMT36


The AECOM report does indicate these concentrations, though they are not representative oflikely Minnelusa concentrations near the project area. These concentrations likely pertain to Minnelusa wells near the Black Hills Monocline on the eastern flank of the PRB. Deep basin samples are much higher than indicated for TDS values.

Wells, D.K., J. F. Busby, and K C. Glover, 1979. "Chemical Analyses of Water from the Minn el us a Formation and Equivalents in the Powder River Basin and Adjacent Areas, Northeastern Wyoming." Prepared by USGS, Published by Wyoming Water Planning Program, Report No. 18,

State Engineer's Office, Cheyenne, WY.

The following revision is suggested:

"TDS concentrations increase basinward to around 2,400 mg/L [2,400 ppm]. (AECOM, 2014). In the deeper portions of the Powder River Basin in Campbell County, TDS concentrations in the

Minnelusa exceed 10,000 mg/L, and often exceed 100,000 mg/L (Wells et al., 1979)."


CMT37

Section 3. 7.1; Page 3-79; Line 34-39

Discussion confuses NRC guidance on long-term representativeness demonstration. The following revision is suggested:

"Onsite data were supplemented with short-term and long-term data from a meteorological station at the Antelope Coal Mine to provide a historical perspective. Long-tern1 data and concurrent

baseline-year data fr01n Antelope were compared to demonstrate representativeness of the

baseline period in the general vicinity ~f the Reno Creek Project. This procedure cm?forms to

Regulat01y Guide 3.63, Section C-1: To determine whether the period during which the onsite

data was collected is representational, compare a concurrent period ~f n1eteorological datafi·on1

a National Weather Se111ice (NWS) station with the long-term meteorological data.from that NWS

station. The Antelope Mine station, located about 32.2 km [20 mi] southeast of the proposed Reno Creek ISR Project area and operated by Inter-Mountain Laboratories, started collecting hourly meteorological data in 1986."

CMT38

Section 3. 7.2.1; Page 3-84; Line 31-34

The Taffner residence shown on Figure 3-1 does not exist. AUC is providing a revised Figure 3-1 with the Taffner residence removed, which W<J.S originally submitted in the Reno Creek ISR Project Round 1 RAI Response Package, June 2014, Appendix E SEIS Figures (Land Use). The following revisions are suggested:

Delete "Therefore, the nearest residence to the proposed Reno Creek ISR Project area is about 0.68 km [0.42 mi] northwest (AUC, 2012a)". Additionally, remove all references to the Taffner residence in DEIS Section 3.2, Land Use.


GJ Proposed Reno Creek Project Boundary

0 Five Mile Review

• Residence

.A. CBM Compressor Station

e Cities and Towns

- Major Road (Paved)

--Road

Pipeline Operator

=-- Belle Fourche (Crude Oil)

=-=- Fort Union Gas Gathering (Natural Gas)

c-==: Kansas-Nebraska Gas Gathering (Natural Gas)

_,,_, Kinder Morgan Operating, LP. (Natural Gas)

-··-· Thunder Creek Gas Services, L.L.C. (Natural Gas)

= Western Gas Resources (Natural Gas)

Wyoming State Geological Survey, 2002 Wyoming Geographic Information Science Center, 1998

4 •••c:==i•••==:::::iMiles

Land Use Description

!:!:!I Irrigated Cropland

l.'.:<;.:;-j Agricultura l

~ Non-Irrigated Cropland

OIIIID Urban/Built-Up Area

~ Surface water Features

s

CMT39

Section 3. 7.2.1; Page 3-84; Footnote

Definition of PM10 is not correct in footnote. Suggest citing definition in 40 CFR Part 50, Appendix J to Part 50, Reference Method for the Determination of Particulate Matter as PM10 in the Atmosphere, defines PM10 as "the mass concentration of particulate matter with an aerodynamic diameter less than or equal to a nominal 10 micrometers in ambient air." Note also that the definition provided in the draft SEIS actually describes coarse PM. Appendix 0 to Part 50, Reference Method for the Determination of Coarse Particulate Matter as PM10-2.s in the Atmosphere, defines PM10-2.s as particulate matter having an aerodynamic diameter in the nominal range of 2.5 to 10 micrometers, inclusive.

CMT40

Section 3.12.1; Page 3-118; Line 3

AUC must receive the NRC license prior to most construction activities. Although, prior to operations all baseline monitoring reports are required to provide data on radiological conditions that would be used to evaluate potential changes in future site conditions from routine facility operations or accidental or unplanned releases. For clarification, the following revision is suggested:

"Therefore, if the NRC issues the license in the future, it will be conditioned on receiving this updated information prior to the pre-operational NRC inspection and start of operations."

CMT41


Page 3-53 of the DEIS says uranium concentrations in the PZA are as high as 0.661 ppm which conflicts with 0.607 stated on Page 3-122. (Reference 007 TR_Addendum 2.7-A_B, Table 2.7B-31: PZM Zone Monitoring Results, Well PZM2 [AUC LLC. 2012b]). The following revision is suggested:

"The uranium concentrations exceeding the MCL ranged from 0.0304 to 0.661 mg/L [0.0304 to

0.661 ppm]."

August2016 Page 12 of26

CMT42

Section 3.13.1; Page 3-126; Line 26-27

This sentence in the DEIS references the ER Section 4.13.1.1.3.2 TENORM, but it misinterprets the meaning of the section. It does not say AUC will discharge development water to the pits. It says pump test well water will be discharged under a WYPDES permit.

Remove the following text: "The applicant proposes to obtain a WDEQ WYPDES permit to discharge well development water into mud pits adjacent to drilling pads (AUC, 2012a) on each wellfield that is constructed".

CMT43


AUC has received a conditional aquifer exemption from the EPA pending the collection of water quality data from the permitted discharge zones. The following revision is suggested:

"Before the permitted Class I deep disposal wells can be operated, an aquifer exemption determination must be made by the WDEQ with EPA approval (draft SEIS Section 2.1.1.1.4) for the aquifer (or portion thereof) that is the discharge zone for the disposal well. A UC has received

a conditional aquifer exen1ption fiwn the EPA pending the collection of water quali~v data .fi'om the permitted discharge zones."

CMT44


SeeCMT 18.

CMT45


Clarification of the UIC application supporting information. The following revision is suggested: j .

"Additionally, the applicant's permit application explained that each proposed Class I deep d{sposal well is located between thick confining layers oflow-permeability shale that separate the receiver interval from potential underground sources of drinking water and that there are no artificial penetrations within the Areas o.f Review for any of the proposed Class I wells that could

allow for vertical migration o.ffluid out o.f the permitted discharge zones."


CMT46


The White Mesa Mill is now legally owned by Energy Fuels Resources Inc., not Denison. The following revision is suggested:

"The applicant has identified the Pathfinder Mines Corporation; Shirley Basin (Wyoming) Facility; the Energy Fuels Resources Inc. White Mesa Uranium Mill, Blanding, Utah; and the EnergySolutions LLC, Clive Disposal Facility, Clive, Utah, as potential disposal locations for solid byproduct material, but a disposal agreement is not yet in place (AUC, 2012a)."

CMT47


The White Mesa Mill is now legally owned by Energy Fuels Resources Inc., not Denison. The following revision is suggested:

"The Energy Fuels Resources Inc. White Mesa site is an operating conventional uranium mill in

Blanding, Utah, approximately 1, 070 km [666 mi} (A UC, 2012a) from the proposed Reno Creek

project."

CMT48


In addition to the oil and gas companies listed in the following text, Ballard Petroleum, True Oil, EOG, and Peak Powder River were also consulted and have a working relationship with AUC. For clarification, the following revision is suggested:

"To mitigate the impacts of surface disturbance during construction, the applicant would (i) restore and reseed areas disturbed by facility construction, production unit development, and pipeline installation as soon as practicable; (ii) coordinate construction efforts with oil and gas production companies operating within the proposed project area (currently Williams Production RMT Company, Yates Petroleum Corporation, Lance Oil and Gas Company, and Bill Barrett Corporation, Ballard Petroleum, True Oil, EOG, and Peak Powder River); (iii) use existing county roads and oil and gas access roads to the extent possible to limit new access road construction; (iv) utilize existing topography during access road construction to minimize cut and fill; (v) minimize secondary and tertiary access road widths; and (vi) locate access roads, pipelines, and utilities in common corridors (AUC, 2012a)."

August2016 Page 14 of26

CMT49


See CMT 48.

CMTSO


State-owned lands in Wyoming are administered by the Office of State Lands and Investments,

Board of Land Commissioners (BLC). AUC has committed to submitting a written request to the BLC to restrict hunting on the parcel of state owned land within the proposed project area (AUC, 2014a). The following revision is suggested:

"The applicant would submit a request to the Office o.f State Lands and Investments, Board of Land

Commissioners (BLC) to restrict hunting within proposed production .units constructed on state- ' owned land within the proposed project area."

CMT51


To further clarify the commitment of the use of BMPs to reduce potential erosion impacts, the following revision is suggested:

"A UC's Storm Water Pollution Prevention Plans (SWPPP.-,~, when approved by WDEQIWQD,

will include a conunitment to employ Best Management Practices (BMPs) where applicable. These

activities, however, would result in SMALL impacts if equipment operators adopt construction BMPs to either prevent or substantially reduce erosion. (NRC, 2009)"

CMT52


SeeCMT 18.

CMT53


The SM and OM Units have varying degrees of continuity, and may not be present across entire project area. For clarification, the following revision is suggested:


"The shallow aquifers (the SM and OM Units, where present) have poor water quality and are hydraulically separated from locally and regionally important aquifers."

CMT54


AUC plugged and abandoned the Taffner #1 well in accordance with WDEQ rules and regulations in August, 2015. The WSEO, WDEQ and EPA were notified upon completion. The following revision is suggested:

"The applicant has plugged and abandoned the Taffner #1 well located at the Taffner residence in accordance with WDEQ rules and regulations (AUC, 2012a, 2014b).

CMT55

Section 4.6.1.3; Page 4.,..72; Line 25-27

The WDEQ Class I permit does not have requirements for disposal capacity; thus, NRC effluent . limits and other NRC safety regulations are not pertinent to the WDEQ Class I UIC Permit application. Additionally, Section 4.14.1.1.3 concerns "Aquifer Restoration Impacts" and not specifically the UIC permit. The following revision is suggested:

Delete "The applicant has obtained a WDEQ Class I disposal permit that requires adequate disposal capacity, the NRC effluent limits, and other NRC safety regulations as explained in draft SEIS Sections 2.1.1.1.6 and 4.14.1.1.3."

CMT56 !

; Section 4. 7.1; Pag~ 4-75; Line 30

AUC has submitted the air quality permit application for the Reno creek Project. The permit has been determined to be complete and is presently undergoing technical review. For clarification, the following revision is suggested:

"The applicant has submitted an air quality permit to the WDEQ and approval is pending (~ee draft SEIS Table 1-2). "

CMT57


SeeCMT39.


CMT58


The discussion mentions only gaseous pollutants and should address particulates for completeness. The following revision is suggested:

"Uranium JSR activities would not occur, and the pollutants associated with these activities would not be generated. The No-Action Alternative eliminates a source of gaseous and particulate emissions that would contribute to the ambient pollutant concentrations. "

CMT59


With the recent decline in coal production in the region near the proposed Reno Creek Project, it

is anticipated there will be an excess of technical/skilled workforce to support the proposed project needs through all project phases. The following revision is suggested:

"The recent losses of coal employn1e11t, especially those which are regarded as long term will

allow AUC to hire higher technical/skilled positions local~v without importing many new employees. It will fi1rther reduce the adverse socioeconomic effects of the declining coal indust1y."

CMT60

Section 4.i2.2; Page 4-122; Line 26-27

Se~CMT 50.

CMT61


SeeCMT46.

CMT62


The Class III aquifer exemption was been approved in October 2015 by the EPA. The defined aquifer or its portion meets criteria in 40 CFR 146.4 for exemption as an underground source of drinking water. For clarification, the following revision is suggested:

Delete: "Before the permitted wells can be operated, an aquifer exemption determination must be made by the EPA for the aquifer (or portion thereof) that is the discharge zone for the injection


well. In this regard, EPA would evaluate the aquifer and determine whether it meets 40 CFR 146.4 for exemption as an underground source of drinking water (currently pending). The NRC would require treatment systems to be approved, constructed, operated, and monitored to ensure release standards in 10 CFR Part 20, Subparts D and K are met."

Add: "The applicant has received a conditional aquifer exemption for the permitted Class I ·wells

fiwn the EPA pending collection of water quality data.fi·om permitted discharge zones. The de.fined

aquifer or its portion 1neets criteria in 40 CFR 146.4for exemption as an underground source of

drinking water. "

CMT63


It is important to note that the Madison (and Minnelusa) aquifers used for the town of Gillette's water supply are located along the eastern flank of the PRB and at much shallower depths than encountered near Reno Creek. For clarification, the following revision is suggested:

" ... of Gillette. These Madison wells are located east of Gillette, and 1nore than 50 miles northeast

of the Reno Creek JSR Project, and the Madison at these water supply wells is encountered at

sign(ficantly shallower depths. " '

CMT64


SeeCMT29.

CMT65

Section 5. 7.1.1; Page 5-44; Line 16-28

The discussion overstates the contribution of ISR projects as 2% of total N02 in the far-field

region. Table 2-7 of the PRB Coal Review II Task 3A report (BLM 2014a) shows 208,000 tons per year of NOx emissions in 2020 within the 4-km domain, which encompasses the PRB study

area.

The DEIS discusses nirte active ISR projects, with emissions on the same order as Reno Creek. Combined NOx emissions from these ISR projects would be approximately 225 tons per year (inferred from Table M. 70 in reference BLM, 201 Sa), or about 0.1 % of the statewide NOx emissions. Therefore, the draft SEIS appears off by an order of magnitude. While the quality of the PRB Coal Review emission inventory has been questioned by BLM, reported actual emission inventories show NOx emissions from regional coal production, power generation, pipeline


compression, and transportation far in excess of the roughly 11,250 tons/year inferred by the 2% figure in the DEIS.

The Three-State Air Quality Study as summarized by ENVIRON, the Western Air Resources Council, and the University of North Carolina in April, 2015, projects total statewide NOx emissions at 200,000 tons in 2018. This is corroborated by the National Emissions Inventory database, maintained by EPA, which shows 2011 NOx emissions from all source types in Wyoming to be 208,000 tons. The same database shows 2011 NOx emissions within the region of the proposed Reno Creek Project (Campbell, Converse, Crook, Johnson, Natrona, and Weston counties) to be 82,267 tons (NEI, 2011). A majority ofthis area falls within the region of influence (50 mile radius of Reno Creek) and includes most of the coal mines, power plants, and oil and gas development in northeast Wyoming. The DEIS should be revised to state that ISR projects would contribute on the order of0.3% of the NOx emissions within the region of influence. The following revision is suggested:

Delete "The only pollutant generated from uranium extraction activities that contributes more than one percent to the overall emission levels is nitrogen dioxide at two percent (BLM, 2015a)."

Add "For example, NO,- emissions .fi·om uranium extraction activities -would constitute

approximately 0.3% of the overall emissions of oxides o.fnitrogen in the region of iT?fiuence."

Note also that nitrogen dioxide is primarily formed in the atmosphere; thus, not inventoried as an emitted pollutant. Rather, it is modeled as an ambient pollutant based on its precursor NOx emissions.

CMT66


The air particulate monitoring stations only measure the total air volume that passes through the air particulate sampling filters. The following revision is suggested:

"The air particulate monitoring program would be conducted using solar powered stations that employ electronic airjlmv control, and that maintain digital records o.f total air volume passing

through the air particulate sampling.filters during the collection periods (AUC, 2-14b )."

CMT67


Some confusion regarding airborne vs. gamma monitoring. The following revision is suggested:

"The applicant proposes to measure ambient radon (Rn-222) concentrations in air continuously, using track-etch radon detectors replaced quarterly. "


CMT68


RadTrack detectors are no longer in use. For clarification, the following revision is suggested:

Delete the word "Radtrack'', "RadTrak" or "Radtrak" here and throughout the document. Substitute "track-etch radon detector" throughout the document.

CMT69


The text refers to the baseline sampling program as opposed to the operational monitoring program. The following revision is suggested:

Delete "Additionally, consistent with Regulatory Guide 4.14 and NUREG-1569 (NRC, 2003, 1980), radon (Rn-222) concentrations would be measured quarterly over a 1-year period (AUC, 2012a, 2014b)."

CMT70


The first Production Unit Hydrologic Data Package is reviewed and approved by the WDEQ and sent to the NRC for review and verification (reference "The Reno Creek ISR Project, Campbell County, Wyoming, RAI Response Package: Technical Report Round 1; RAI 57 Response" [ AUC LLC. 2014b]). The following revision is suggested:

"The report would then be submitted to the Wyoming Department ~f Environmental Quality

(WDEQ) for review and approval before JSR operations com1nence. A UC wi.11 submit the first

Production Unit Hydrologic Data Package to NRC stafffor review and ver(fi.cation. A UC will

submit all subsequent Production Unit Hydrologic Data Packages to NRC staff for review".

CMT71


To further clarify, the following revision is suggested:

Revise sentence to state: "Therefore, the applicant does not intend to conduct vegetation, food, or fish sampling during operations, because the predicted dose to an individual from these pathways would be less than 5 percent of the applicable radiation protection standard (AUC 2012a)."


CMT72


To further clarify, the following revision is suggested:

"Hmvever, in response to NRC RAJs, the applicant has committed to provide data for a11 additional round o.fvegetation samples (AUC, 2015b; NRC, 2015)."

CMT73

Section 8.2.2; Page 8-3; Overall Discussion

Another noteworthy benefit of uranium production from the proposed project is reduction in C02 emissions (Environment: Emissions Prevented. Retrieved August 10, 2016, from http://www.nei.org/Knowledge-Center/Nuclear-Statistics/Environment-Emissions-Prevented). The following revision is suggested:

"According to NE!, nuclear power avoided production of 564 million metric tonnes o.f C02 in 2015. The US nuclear fleet uses approximately 50 million pounds per year and the applicant proposes to produce approximateZv 2 million pounds per year.from a local US source. Therefore, the uranium produced.from the Reno Creek Pro_ject will support the avoidance of 22.6 million metric tonnes o.fC02 each year of its life. This is at least three tin1es the amount generated by the project's consumption of electricity, if all sourced by coal."

CMT74

Section 9.1; Page 9-15; Line 12-13

Restoration does not apply to Class I wells. The following revision is suggested:

Delete: "For the Class I deep disposal wells, the primary restoration methods would be ... "

CMT75

Appendix C; Page C-1; Line 30

Suggest enhanced discussion to clarify that WDEQ/ AQD permitting requirements are more stringent than other states, as follows:

"Regulat01y determinations for air permits o.ften primarily focus on stationmy sources, although Wyoming's New Source Review program also scrutinizes mobile and .fitgitive sources, even for Minor Source air permits. Since mobile a11dfugitive sources compose ... "


CMT76

Appendix C; Page C-2; Footnote

SeeCMT39.

CMT77


Change reference to AUC Modeling Protocol and Results, from Appendix D to Appendix A.

CMT78


SeeCMT77.

CMT79

Appendix q; Page C-3; Line 37

SeeCMT77.

CMTSO

Appendix C; Page C-10; Line 8.

Strengthen case for predominance of fugitive dust: " ... settle out within a short distance ~f the

emission source. Wind erosion contributes an additional 5% ~f total PMuJ emissions. Fugitive dust fi·om wind erosion at moderate wind speeds is also su~ject to settling, due to particle sizes near

the suspension threshold, the increase in concentration gradient, and downwind changes in land swface roughness. Therefore, the total .fugitive fiYtction suNect to settling could be as much as

98% ~f total PM10 emissions. The nature of ~he proposed project's emissions ... "

CMT81

Table 6-1; Page 6-3; Access Restrictions; Paragraph l; Line 1

AUC has not proposed to install a radium settling pond as part of the proposed Reno Creek Project. The following revision is suggested:

Delete "radium settling and".


CMT82

Table 6-1; Page 6-3; Access Restrictions; Paragraph 2; Line 1

AUC has stated it will install fencing around production wellfields, but not around individual patterns. The following revision is suggested:

Delete "patterns" after wellfield.

CMT83

Table 6-1; Page 6-3; Access Restrictions; Paragraph 6; Line 1

There is no BLM surface land within the proposed project area, therefore AUC will work with the BLC, the Wyoming Game and Fish Division, and private landowners to limit recreational activities (primarily hunting) within the proposed project area, to the extent practicable.

The following revision is suggested: Remove the reference to Bureau of Land Management (BLM) and replace with "Office of State Lands and Investments (BLC)".

CMT84

Table 6-1; Page 6-7; Water Use; Paragraph 3; Line 1

Class I wells are permitted under and must comply with the WDEQ Class I UIC permit and not governed by NRC effluent discharge limits.

CMT85

Table 6-1; Page 6-8; Excursions; Paragraph 3; Line 1

Monitor wells have been specifically excluded from 5-year MITs. Reference Action Items Public

Meeting October 8, 2015 (ML15296A541), Draft LC 10.5 Response. For clarification, the following revision is suggested:

"Conduct precise and periodic mechanical integrity testing of all production, il!fection and

monitoring wells prior to their use. All production and il?fection wells will be mechanical integrity

tested during their use, to limit the likelihood ~f well integrity.failure during operations."

CMT86

Table 6-1; Page 6-8; Excursions; Paragraph 9; Line 1

Insert "geologically" before confined.


CMT87

Table 6-1; Page 6-8; Restoration/Reclamation; Paragraph 4; Line 1

The first Production Unit Hydrologic Data Package is reviewed &nd approved by the WDEQ and sent to the NRC for review and verification (reference "The Reno Creek ISR Project, Campbell County, Wyoming, RAI Response Package: Technical Report Round 1; RAI 57 Response" [AUC LLC. 2014b]). The following revision is suggested:

"Submit the Production Unit Hydrologic Data Packages to the Wyoming Department of Environmentai Quality (WDEQ) for review and approval before ISR operations commence. AUC will submit the first Production UI?-it Hydrologic Data Package to NRC staff for review and verification. AUC will submit all subsequent Production Unit Hydrologic Data Packages to NRC staff for review".

CMT88

Table 6-1; Page 6-10; Cultural and Historic Resources; Paragraph 1and3

The following revision is suggested:

·Change the word Unanticipated to Inadvertent to be consistent with tlie rest of the DEIS.

CMT89

Table 9-1; Page 9-14; Unavoidable Adverse Impacts

SeeCMT 84.

CMT90

Figure 2-8

AUC received its UIC Class I Permit in June 2015. AUC has included an updated Figure 2-8, Location of Proposed Class I Deep Disposal Wells (AUC, 2014a) based on the UIC Class I Permit.

CMT91

Figure 2-9

AUC received its UIC Class I Permit in June 2015. AUC has included an updated Figure 2-9, Schematic of the Design of Class I Deep Disposal Well (AUC, 2012b) based on the UIC Class I Permit.

, August 2016 Page24 of26

,.

Campbell

1

,.

I ~---

...... .. i

~1---- ·-··-··-+·-··· ~

Legend

Reno Cree}. Proposed 1r.1ect1on Wetl (4)

c::J 8-13 n · ULEW

c::J 1320 n -AOR

c::J 391'• n · COi

// /) ouaner. owner. AOR

D Propose<J ISR Processir'1 Plam

...., Reno Creel< Pr'O)ect Area

!:l.000 ----====---- Fe~t 0 2 000 4.000

AUC L LC Figure 1

Topography with Injection Well Locabons & Areas of Rev1ev.'

O' Grou d Su ce

Not to Scale

All depths la 1ve to GL.

6,500' -Fox Hills 6,750' --

ewrs Shale

7,215' -- r:::::::I Teckla Sandstone r:::::::I

r:::::::I

7.635'-D

Teapo Sandstone r:::::::I r:::::::I

Depths based on pro;ected dept sat IW-1

~---- 12 114' Dia (G-1 .050')

O'

--1----- 9 5/a·. 31311', J-55, s c Casing (0-1 ,035 ')

.__ ____ Cern (G-1 035')

050'

~----- 7 7/P." 1 iameter Hoe (0- 7.860')

-----1------ Pack:er Fl id

5112" 1711 -80 -c Casing 1/'''1·-+------ (O- 7,BOO'l

..._ _____ Cement (0 - 7.800')

2 us·. 6 .5#, L-80, c EUE Tubing ,,.,.."-'I--+------ (I nternally Coaled ·w,1 TK-99)

(0 - 7.100': 1 joint tail pipe &WLEG)

1 ... ~..-+------ L-1 00n / O, Too (7,065')

x-~-+------ 472-237 Ho et Pac er coa ed ·wJ PA-400 B] (COE 7.070')

.L-J. ------ Teckla Perfcra!ed Zone

Fl]~ ,,_p,"~"'"-

rl1f: FIEND CREEK PROJECT

· Figure M-1 Proposed Injection Well Schematic

TD 7.850'


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