Dir Draft Ea 2-13-09

Draft Environmental Assessment 1

DRAFT ENVIRONMENTAL ASSESSMENT

Kaibab JV Exploration Drilling Program Tusayan Ranger District Kaibab National Forest

Coconino County, Arizona

February 2009


TABLE OF CONTENTS

Chapter 1. Need for the Proposal ................................................................................8

Introduction.................................................................................................................8

Statement of Purpose and Need ...................................................................................8

Background ...............................................................................................................10 Location and General Setting of Projects in Proposed Plan ....................................10 Tusayan Ranger District Uranium Exploration and Mining History .......................11

Summary of Direction Provided by the USFS’s Existing Resource Management Plans

..................................................................................................................................16

Authorizing Actions, Relationship to Statutes and Regulations...................................18

Decisions to be Made Based on this NEPA Analysis ..................................................18

Public Participation ..................................................................................................18 Introduction ...........................................................................................................18 Preliminary Summary of Issues and Concerns .......................................................19

Chapter 2. Proposed Action and Alternatives...........................................................21

Introduction...............................................................................................................21

Alternatives Analyzed in Detail..................................................................................21 The No Action Alternative.....................................................................................21 The Proposed Plan of Operations Alternative.........................................................21

Chapter 3. Affected Environment..............................................................................32

Regional Setting and Land Use..................................................................................32 Introduction ...........................................................................................................32 Southern Tusayan Woodland (EMA 8) ..................................................................32 Tusayan Forestland (EMA 10) ...............................................................................33 Existing and Foreseeable Land Uses ......................................................................34

Geology, Pedology, and Hydrology ...........................................................................34 Geology.................................................................................................................34 Pedology (Soils) ....................................................................................................36 Watershed, Subsurface Hydrology, and Hydrogeochemistry..................................38 Possible Causes of Seasonal Increases of Uranium Concentration in Horn Creek Waters ...................................................................................................................61

Air Quality, Radiation, and Noise Levels ...................................................................65 Air Quality ............................................................................................................65 Background Radiation and Radon Gas...................................................................66 Noise .....................................................................................................................66

Biological Resources .................................................................................................67 Introduction ...........................................................................................................67


Field Botany ..........................................................................................................67 Wildlife Biology....................................................................................................72 Range, Noxious, and Invasive Exotic Weeds .........................................................80

Cultural Resources ....................................................................................................81 Introduction ...........................................................................................................81 American Indian Consultations ..............................................................................81 Culture History......................................................................................................81 Previous Research .................................................................................................83 Survey Methods.....................................................................................................84 Survey Results.......................................................................................................85

Socioeconomic Resources and the Environmental Justice Baseline............................89 Coconino County...................................................................................................89 Kaibab National Forest Economic Contributions ...................................................92

Chapter 4. Environmental Effects .............................................................................94

Introduction...............................................................................................................94

Impacts on Existing and Foreseeable Land Uses .......................................................94

Impacts on Geology, Pedology, and Hydrology .........................................................96 Effects on Soils and Watershed..............................................................................96 Geological and Subsurface Hydrological Impacts ................................................100 Worst Case Impacts on Hydrogeochemistry.........................................................102 Worst Case Colorado River Water Impacts..........................................................102 Worst Case Havasu Creek Water Chemistry Impacts ...........................................106

Effects on Air Quality, Radiation, and Noise Levels.................................................108 Impacts on Air Quality ........................................................................................108 Impacts on Background Radiation and Radon Gas Levels....................................109 Impacts on Noise Levels ......................................................................................110

Impacts on Biological Resources .............................................................................112 Plant Impacts .......................................................................................................112 Wildlife Impacts ..................................................................................................116 Impacts on Range, Noxious, and Invasive Exotic Weeds .....................................118

Impacts on Cultural Resources ................................................................................120 Paleowest Recommendations...............................................................................120 Summary .............................................................................................................126

Impacts on Socioeconomic Resources and the Socioeconomic Aspects of

Environmental Justice .............................................................................................126

Cumulative Impacts .................................................................................................128 Introduction .........................................................................................................128 Modeling of Future Exploration and Discovery Quantities...................................130 Cumulative Impacts on Racial Minorities ............................................................135 Cumulative Impacts on the Economically-Disadvantaged ....................................144 Cumulative Impacts of Breccia Pipe Mining on Coconino County.......................146


Chapter 5. Distribution and Draft EA Preparation................................................163

Draft EA Distribution List .......................................................................................163

List of Preparers......................................................................................................168 Lead Preparer, Consultant to DIR Exploration, Inc.: Mr. Terry W. Fox...............168 Second Preparer, DIR Exploration, Inc. Managing Geologist: L. D. Turner ........169 Editor and reviewer, DIR Exploration, Inc. VP: I.L. Turner ................................169

References ...............................................................................................................170

Appendix – Production Function Estimations .........................................................178

Introduction.............................................................................................................178

Equation 1...............................................................................................................178

Equation 2...............................................................................................................180

Equation 3...............................................................................................................182

LIST OF FIGURES

Figure 1. Index map, Proposed Plan of Operations.......................................................11 Figure 2. Stratigraphic position of uranium ore in Arizona breccia pipes......................12 Figure 3. Cartoon showing the various types of solution-collapse features seen in

northwestern Arizona.............................................................................................13 Figure 4. One interpretation of the distribution of collapse breccia pipes in the Tusayan

Ranger District, Kaibab National Forest, Coconino County, Arizona. ....................15 Figure 5. Proposed Plan of Operations index and access map.......................................24 Figure 6. Late 1980s uranium exploration drilling at the Garfield Prospect. .................25 Figure 7. Map showing direction of Redwall-Muav aquifer ground water flow in the

Tusayan Ranger District area. ................................................................................40 Figure 8. Dissolved uranium of Colorado River in context...........................................43 Figure 9. Dissolved arsenic of Colorado River in context.............................................44 Figure 10. Dissolved metal loads and concentrations, Colorado River..........................46 Figure 11. Colorado River dissolved arsenic. ...............................................................47 Figure 12. Colorado River dissolved uranium. .............................................................47 Figure 13. Table 7 of Monroe et al. (2004)...................................................................48 Figure 14. Evidence of causal relationship between dissolved uranium content and water

gross alpha-radioactivity. .......................................................................................49 Figure 15. Locations of south rim springs and creeks studied by USGS. ......................50 Figure 16. Taken from Figure 24 of GJBX-143(81) .....................................................53 Figure 17. Orphan Mine area ground water recharge area with USGS (2005) average

residence time of waters.........................................................................................55 Figure 18. Evidence of uranium-sulfate complexing in the Redwall-Muav aquifer waters

emerging from the springs and creeks on the south rim of the Grand Canyon.........58 Figure 19. Weak evidence of uranium-carbonate complexing in the Redwall-Muav

aquifer waters emerging from the springs and creeks on the south rim of the Grand Canyon. .................................................................................................................60


Figure 20. Summary model of Orphan Mine contribution of uranium to the Redwall-Muav aquifer. ........................................................................................................63

Figure 21. Overflow of Orphan Mine aerial tramway bucket could have spilled uranium ore into the west side of the Horn Creek drainage cell. ...........................................64

Figure 22. Drill rig at Garfield prospect, dwarfed and camouflaged by ponderosa pines...............................................................................................................................95

Figure 23. Exploration drilling at Kaibab JV Hummer Prospect, early 1990s, looking easterly. ...............................................................................................................101

Figure 24. Late 1980s to early 1990s exploration drilling area at the Kaibab JV’s Hummer Prospect, looking northerly in 2007.......................................................101

Figure 25. Surface drill hole pattern typically used to explore an economically-mineralized breccia pipe. .....................................................................................104

Figure 26. Average residence time of Redwall-Muav aquifer ground water on Coconino Plateau.................................................................................................................105

Figure 27. Dust emitted by drill rig before drill bit is covered by rock (the bit is still at the top of new hole). ............................................................................................109

Figure 28. Noise intensities around a typical water well drilling rig. ..........................111 Figure 29. Log10-log10 cumulative frequency diagram of 1965-2008 U3O8 spot

price/pound..........................................................................................................132 Figure 30. Modeled annual total bonded disturbance acreage/square mile of prospective

USFS and BLM ground as a function of lagged uranium price. ............................132 Figure 31. Modeled annual total exploration drill holes/square mile of prospective USFS

and BLM ground as a function of lagged uranium price. ......................................133 Figure 32. Modeled annual economically-mineralized breccia pipe discovery rate/square

mile of prospective USFS and BLM ground as a function of lagged uranium price.............................................................................................................................133

Figure 33. Index map showing red-outlined lands currently open to uranium exploration and mining, and which are expected to continue to yield economic discoveries of uranium-mineralized breccia pipes.......................................................................134

Figure 34. Model showing potential long-run effect of ‘wet’ exploration drilling on Redwall-Muav ground water discharging in the Havasu Creek drainage. .............136

Figure 35. Detailed map showing average residence time of Redwall-Aquifer ground water in the Coconino Plateau proximal to the Grand Canyon..............................137

Figure 36. Detailed map showing elevation of the top of Redwall-Aquifer ground water, and its direction of flow, in the Coconino Plateau proximal to the Grand Canyon.138

Figure 37. 25 ppm U solution worst-case scenario. ....................................................141 Figure 38. 0.18 to 25 ppm U solution scenario. ...........................................................141 Figure 39. 0.18 ppm U solution (Orphan Mine) scenario............................................142 Figure 40. Comparison of per capita income gain between the labor markets of fossil

energy-focused western US counties and those western US counties without fossil energy (and mineral) industries. ...........................................................................146

Figure 41. Mesa County, Colorado, illustration of per capita income growth in mining, construction, and services and professions caused by 1974-1989 mining industry activity.................................................................................................................147


Figure 42. An example of what northern Arizona breccia pipe uranium exploration and mining is not: Extremely rapid growth of the coal bed methane industry in western Colorado..............................................................................................................154

Figure 43. Energy-focused Counties of the western USA: mining industry wages in context.................................................................................................................155

LIST OF TABLES

Table I. Lode Mining Claims Subject to Proposed Plan of Operations ...........................10

Table II. Reported Economically-Mineralized Breccia Pipes ........................................16

Table III. Permits, Approvals, and Authorizing Actions Necessary for Execution of the Proposed Plan of Operations..........................................................................................19

Table IV. Ongoing USFS Projects with Significant Surface Impact ..............................35

Table V. Proposed Plan Project Area Soils ...................................................................38

Table VI. Colorado River Dissolved Trace Metals in Context.......................................43

Table VII. South Rim Springs and Creeks ....................................................................51

Table VIII. Havasu Creek and Little Colorado River Averaged Concentration and Annual Release Data from USGS OFR-96-614 .............................................................51

Table IX. Horn Creek Repeated Water Analyses (USGS).............................................54

Table X. Fitzgerald (1996) Horn Creek Seep Analyses .................................................61

Table XI. Total Suspended Particulates, 10 µ-m and Smaller, Collected at Hance Camp by the National Park Service .........................................................................................65

Table XII. U.S. Fish and Wildlife Service List of Plants in Coconino County, AZ........69

Table XIII. USDA Forest Service Southwestern Region List of Sensitive Plants found on the Kaibab National Forest ............................................................................................70

Table XIV. Special-Status Plant Species that May Occur in or near the Project Areas ...72

Table XV. Wildlife Species Listed under the Endangered Species Act and Identified for Coconino County, Arizona by the U.S. Fish and Wildlife Service .................................73

Table XVI. Species from the 2007 Southwestern Region (R3) Forest Service Sensitive Species List whose Range Overlaps the Williams or Tusayan Ranger District. ..............74


Table XVII. Faunal MIS Species on Kaibab National Forest ........................................76

Table XVIII. Arizona Partners in Flight Priority Species ...............................................78

Table XIX. Summary of Sites Located in the Bozo Prospect ........................................85

Table XX. Summary of Isolated Finds Discovered in the Bozo Prospect ......................85

Table XXI. Summary of Sites Located in the Garfield Prospect....................................86

Table XXII. Summary of Sites Located in the Grandpa Prospect ..................................86

Table XXIII. Summary of Isolated Finds Discovered on the Grandpa Prospect.............86

Table XXIV. Summary of Sites Located on the Maybe Prospect ..................................87

Table XXV. Summary of Isolated Finds Discovered on the Maybe Prospect ................87

Table XXVI. Summary of Sites Located on the Sze Prospect. ......................................88

Table XXVII. Summary of Isolated Finds discovered in the Sze Prospect. ...................88

Table XXVIII. Summary of sites located in the Two-Squares Prospect.........................89

Table XXIX. Summary of Isolated Finds discovered in the Two-Squares Prospect.......89

Table XXX. Dominant Occupations of the Coconino County Population in 2000 (UA 2005).............................................................................................................................92

Table XXXI. Economic Effects of KNF Lands Management Activities, Coconino County ..........................................................................................................................93

Table XXXII. Aggregate Annual Exploration and Mining Work Quantities, US Forest Service and US Bureau of Land Management Lands, Mohave and Coconino Counties, 1978-1988 ...................................................................................................................129

Table XXXIII. Results of Monte Carlo Simulation of Effect of Mineralized Breccia Pipe Exploration Drilling in Areas C and F on Redwall-Muav Aquifer Ground Water: Sensitivity to Leachate Uranium Concentration ...........................................................142

Table XXXIV. Cumulative Impacts of Mining-Related Minor Concerns ....................149


Chapter 1. Need for the Proposal

Introduction

DIR Exploration, Inc. (“Applicant”), an Arizona Corporation (www.dirxploration.com), and Operator of the Kaibab Joint Venture between DIR and Takara Resources, Inc., (www.takararesources.com) has proposed to the United States Forest Service (“USFS”) of the United States Department of Agriculture (“USDA”), on the behalf of the Kaibab Joint Venture, a program of drilling exploration on six (6) of the Kaibab Joint Venture’s uranium prospects located within the Tusayan Ranger District of the Kaibab National Forest. In support of this proposal, DIR submitted the original version of its detailed Proposed Plan of Operations to the Tusayan District Ranger of the Kaibab National Forest on May 30, 2007. On June 17, 2008, DIR was informed by the Tusayan District that an Environmental Assessment would need to be completed before the District could further process the DIR Proposed Plan, and that DIR itself could choose to conduct this Environmental Assessment. DIR informed the Tusayan Ranger District on September 23, 2008, that the company had decided to begin work on an Environmental Assessment covering the proposed plan. In compliance with the National Environmental Protection Act of 1969, this draft document describes the purpose and need for USFS action with regard to the operating plan proposed by DIR, discloses the details of the company’s proposed plan (as amended) and its ramifications, and the ramifications of the USFS’s no-action alternative to DIR’s proposed operations. This Draft Environmental Assessment (“Draft EA”) was prepared by DIR Exploration, Inc., in compliance with the National Environmental Policy Act of 1969, 40 CFR §1501.7, in order to facilitate the NEPA scoping process mandated for Environmental Assessments by the 36 CFR §220 USFS augmentation of the NEPA procedures. Feedback received from the publication and circulation of this Draft Environmental Assessment will be employed by the USFS, if necessary, to complete a Final EA. Please keep in mind that this report is still subject to Kaibab National Forest’s due-diligence review of its contents and does not, at this time, reflect the considered views and judgment of the USFS or the Kaibab National Forest (“KNF”). Your comments to KNF with regard to this Draft EA will, no doubt, be very helpful to KNF in the completion of its review of the environmental analysis work reported here.

Statement of Purpose and Need

The purpose and need of the USFS with regard to this Draft EA is to review the evidence presented, and then to act upon DIR’s proposal to conduct exploration well drilling operations (the Proposed Action) on six (6) uranium prospects located within the Tusayan Ranger District of the Kaibab National Forest. Implementation of the proposal would incrementally contribute towards meeting world demand for nuclear fuel that is projected


to grow from 68,000 metric tons/year U3O8 in 2005 to 96,000 metric tons/year U3O8 by 2030.1 The Proposed Operating Plan is consistent with the following:

• The General Mining Law of 1872 (20 USC 21-54). Under this law, DIR and the Kaibab JV have the statutory right to enter on open National Forest System lands for the purpose of conducting exploration and mining activities. Exploration and mining activities on such lands that would potentially create significant surface impact are subject to USFS approval of one or more Plan of Operations. In granting such approval, the USFS must adhere to the provisions of NEPA, 36 CFR 228, and 36 CFR 220 before approving, approving with conditions, or denying such a Plan. As enacted and interpreted, the General Mining Law expressly incorporates the “free access” principle of mineral entry on public lands, wherein all valuable mineral deposits in lands belonging to the United States shall be free and open to exploration and purchase.

• The Organic Administration Act of June 4, 1897, the Act eventually creating the National Forest System and specifically mentioning mineral resources:

…Nor shall anything herein prohibit any person from entering upon such forest reservation for all purposes, including that for prospecting, locating, and developing the mineral resources thereof: Provided, that such persons comply with the rules and regulations covering such forest reservations.

See also 16 USC 478.

• The Domestic Minerals Program Extension Act of 1953, which stipulates that each department and agency of the federal government charged with responsibilities concerning the discovery, development, production, and acquisition of strategic or critical minerals and metals shall undertake to decrease, and to eliminate where possible, the dependency of the United States on overseas sources of supply of each such material.

• The Mining and Minerals Policy Act of 1970, which declares that it is the continuing policy of the federal government to foster and encourage private enterprise in the development of domestic mineral resources. This Act covers all minerals, including sand and gravel, geothermal, coal, and oil and gas.

• The Federal Land Policy and Management Act of 1976, which reiterates that the 1970 Mining and Minerals Policy Act shall be implemented and directs that public lands be managed in a manner which recognizes the need for domestic sources of minerals and other natural resources.

1 http://www.eia.doe.gov/oiaf/ieo/uranium.html


• The National Materials and Minerals Policy, Research and Development Act of 1980, which requires that the Secretary of the Interior improve the quality of minerals data in federal land use decision-making.

• The Energy Policy Act of 2005 (Public Law 109-58), which encourages energy efficiency and conservation; promotes alternative and renewable energy sources; encourages a reduction in the degree of dependence of the United States on foreign sources of energy; promotes domestic production and modernization of the electrical grid; and encourages the expansion of the use of electrical energy in the US that is generated via nuclear energy.

Background

Location and General Setting of Projects in Proposed Plan

Introduction The six (6) uranium prospects covered by the subject Proposed Plan of Operations are located within Ecosystem Management Area 8 (EMA 8) and EMA 10 of the Tusayan Ranger District and fall inside T29N, R2E (1 prospect -- Sze); T29N, R3E (3 prospects – Two-Squares, Maybe, and Garfield); T28N, R3E (1 prospect -- Bozo); and T27N, R4E (1 prospect – Grandpa). All townships and ranges cited are with reference to the Gila and Salt River Meridian. See Figure 1 for an index map showing the location of the Tusayan District and Figure 5 for the relative locations of each of the DIR prospects within the Tusayan District of the Kaibab National Forest. Table I describes the lode mining claims involved in each proposed exploration project, in terms of BLM claim identification numbers, section, township, and range.

Table I. Lode Mining Claims Subject to Proposed Plan of Operations

BLM AMC # Claim Acreage Name Section Township Range

373566, 377578 40 Bozo 12 T 28N R 4E 369433-369435 60 Garfield 26 T 29N R 3E 369436-369437 40 Grandpa 6 T 27N R 4E 369441-369443 60 Maybe 15 T 29N R 3E 369444-369445 40 Two-Squares 30 T 29N R 3E 373553-373555 60 Sze 13 T 29N R 2E


Figure 1. Index map, Proposed Plan of Operations.

Tusayan Ranger District Uranium Exploration and Mining History

As Billingsley et al., 1997, remark, there have been two, separate prior episodes of uranium exploration and mining in the Grand Canyon region. In each period, the preponderance of this activity was directed towards the discovery and mine development of the relatively high grade uranium ore found within some of the karst-related structures known as collapse breccia pipes.2 See Figure 2. These pipes are distributed across northwestern Arizona in a manner that follows fractures and faults in the older rocks beneath the Redwall Limestone (Sutphin and Wenrich, 1988)3. Although breccia pipes are widely distributed north and south of the Grand Canyon, not all pipes that have been

2 Billingsley et al., 1997, provide a complete description of the formation of collapse breccia pipes, and recount the history of prospecting and mining that surrounds these natural features. See their ebook, Quest

for the Pillar of Gold: The Mines and Miners of the Grand Canyon, published by the Grand Canyon Association at http://www.grandcanyon.org/booksmore/booksmore_epublications.asp. 3 http://pubs.er.usgs.gov/usgspubs/i/i1778


Figure 2. Stratigraphic position of uranium ore in Arizona breccia pipes.


explored have been shown to contain economic amounts of uranium mineralization. One estimate (Billingsley et al., 1997) is that less than 5% of the breccia pipes in the region are sufficiently mineralized to justify mine development. This fact appears to be a function of largely unrecognized local and regional controls on the original breccia pipe uranium mineralization process, and because of the removal of once-present ore in pipes that have been eroded at or below the Coconino Sandstone stratigraphic level. Complicating the technical exploration process even further, numerous other geological causes have created near-surface features that are very similar to those caused by potentially uranium-mineralized collapse breccia pipes. See Figure 3.

Figure 3. Cartoon showing the various types of solution-collapse features seen in northwestern Arizona.

(1) Breccia pipes that bottom in the Redwall Limestone; (2) Collapse due to dissolution of gypsum beds in the Woods Ranch Member of the Toroweap Formation; (3) Collapse due to dissolution of gypsum beds in the gypsiferous Harrisburg Member of the Kaibab Limestone, and (4) Collapse (with vertical sides, as opposed to the gently-sloping sides of the other three collapse types) of recent sinkholes developed in the limestones of the Kaibab Formation. Taken directly from Wenrich 1992, her Figure 3.


The initial exploration and mining period of the 1950s concentrated, because of limitations in early exploration (prospecting) technology, on collapse breccia pipes that were exposed to view in the deep canyon exposures that characterize the region. For example, the original Hacks Canyon breccia pipes were discovered due to the exposure of pipe-related copper mineralization in the walls of the Hacks Canyon, while the Orphan Mine breccia pipe and its attendant oxidized copper mineralization were visible on the walls of the Grand Canyon. Because the Tusayan Ranger District contains no deep canyons, no breccia pipes were discovered and mined in the Tusayan Ranger District during the first Cold War uranium boom of the late 1940s and 1950s. This situation changed in the mid- to later 1970s, however, as increasing demand for uranium grew with expanding commercial nuclear reactor production of electricity, and with the initial oil supply shocks of the early 1970s and early 1980s. Geologists of Gulf Mineral Resources were among the first to enter the Tusayan Ranger District in the mid-1970s, and using aerial photography, began staking lode mining claims on breccia pipe prospects in the District on the structural geology basis of the then-new collapse model of breccia pipe formation.4 Initial 1981 Gulf Minerals Resources exploration drill holes eventually led to the discovery and development of the Canyon Mine in the Tusayan Ranger District north of Red Butte. The Gulf Minerals exploration reconnaissance work on the flats of the Tusayan Ranger District, and that of the geologists in other companies entering the northwestern Arizona uranium province about the same time, gradually proved that breccia pipes could be discovered outside of the canyon walls area of the Grand Canyon region. Figure 4 shows one interpretation of the numerous possible locations of breccia pipes across the Tusayan Ranger District of the Kaibab National Forest and along the South Rim of the Grand Canyon National Park (Scott 1992).5 By the early 1990s, the second period of uranium exploration and mining ended as a result in the decrease of the world uranium price. The increase in uranium price level that began in 2004, brought exploration and mining companies back into northwestern Arizona at the beginning of the third US and world uranium mining boom. Table II summarizes the published (Billingsley et al., 1997) economically-mineralized breccia pipe discovery history of northwestern Arizona.

4 Wenrich reviews the criteria modern geologists use to locate collapse breccia pipes in northwestern Arizona in Wenrich 1992, which can be downloaded from the United States Geological Survey at http://pubs.er.usgs.gov/usgspubs/ofr/ofr92219 5 http://www.admmr.state.az.us/DigitalLibrary/USBM_MLA/USBM_MLA_005-92.pdf


Figure 4. One interpretation of the distribution of collapse breccia pipes in the Tusayan Ranger District, Kaibab National Forest, Coconino County, Arizona.

From Scott 1992.


Table II. Reported Economically-Mineralized Breccia Pipes

Breccia Pipe Year of U Discovery

Year of Mine Establishment

Year of Mine Decommission

General Location

Orphan 1955 1956 1969 South of Grand Canyon

Hacks Canyon

1945 1945 1975 North of Grand Canyon

Hack 1 1977 1981 1985 North of Grand Canyon

Hack 2 1979 1980 1987 North of Grand Canyon Hack 3 1980 1982 1987 North of Grand Canyon

Pigeon 1981 1984 1991 North of Grand Canyon Kanab North 1981 1987 -- North of Grand Canyon

Arizona 1 1986 1988 -- North of Grand Canyon

Pinenut 1985 1988 -- North of Grand Canyon Canyon 1981 1987 -- South of Grand Canyon

EZ-1 ~1985 -- -- North of Grand Canyon EZ-2 ~1985 -- -- North of Grand Canyon

Hermit 1982 1988 ? North of Grand Canyon

The average ore reserves and grades of the Arizona collapse breccia pipes discovered to date are about 269,600 metric tons of ore at 0.57 percent U3O8, or about 3,400,000 pounds U3O8 per ore body (Finch et al., 2004).6

Summary of Direction Provided by the USFS’s Existing Resource Management Plans

Policies for development and land use decisions on the Kaibab National Forest, including the Tusayan Ranger District, are contained in the Kaibab National Forest Land Management Plan, as amended (2004). The Kaibab National Forest Land Management Plan contains the following generalized direction related to the Proposed Plan of Operations:

• Provide intensive management of prospecting, exploration, and development of mineral resources to protect surface resource and other environmental values.

• Restrict or prohibit surface use in areas with habitat of threatened and endangered and sensitive plant and animal species, and heritage resources nominated or posted to the National Register.

6 http://pubs.usgs.gov/bul/b2004/html/bull2004model_for_solutioncollapse_brecc.htm. Pre-mining reserves at an ore grade cut-off of 0.05% U3O8.


• Impose operating and occupancy restrictions on exploration, development, and operation activities associated with locatable and leasable mineral entry to protect important wildlife habitat.

More specific relevant direction is provided in the Management Plan as follows:

• Heritage resources:

o Provide for heritage resource survey and related site inventory, preliminary evaluation and marking in advance of operations, with preference given to site avoidance over other methods of site protection.

o Include site protection and liability clauses in Forest contracts, permits,

and leases that have the potential to affect heritage resources. Monitor sites within operations areas to determine the effectiveness of protection measures and the need for site stabilization, damage assessment, and liability. At a minimum, inspect and document the findings of at least one site, and not less than 20 percent of the sites, designated for protection within each undertaking. Inspect all sites listed in, nominated to or formally determined eligible for the National Register within each undertaking. Follow damage assessment procedures specified in the Programmatic Agreement and Forest Service Handbook.

o Consult with Indian tribes to obtain tribal advice and input in the

development and implementation of projects proposed in areas of known socio-cultural or religious significance.

• Wildlife:

o Restrict use and occupancy within one-quarter mile of breeding, calving, and fawning areas from May 15 to August 10.

o Restrict use and occupancy within one-quarter mile of raptor nest sites and

permanent waters from April 1 to August 15.

o Limit human activities in or near northern goshawk nest sites during the March 1 through September 30 breeding season so that goshawk reproductive success is not affected by human activities.

• Viewscape: o Restrict surface use and occupancy yearlong in the foreground of heritage

resource sites with National Register status.


Authorizing Actions, Relationship to Statutes and Regulations

The USFS is one of a number of agencies that must issue approvals for the Proposed Plan of Operations. A list of permits, approvals, and authorizing actions necessary to carry out the Proposed Plan of Operations is provided in Table III below.

Decisions to be Made Based on this NEPA Analysis

USFS decision-makers will decide, based on their independent review of the analysis contained in this Draft EA, whether or not to authorize the Proposed Plan of Operations. The USFS’s options when responding to the Plan (DIR Exploration, Inc., 2007) would include: a) accept the Plan as proposed, b) accept with modifications, or c) modify the Plan by incorporating reasonable alternatives.

Public Participation

Introduction

NEPA regulations (40 CFR 1500-1508) require that a federal agency like the USFS deploy a scoping process to identify potentially significant issues in preparation for impact analysis of a Proposed Plan of Operations. According to Chapter 10 of the FSH 1909.15 National Environmental Policy Handbook, Part 11 (2008), the principal goals of scoping are to help refine the proposed action, determine the responsible official and lead and cooperating agencies, identify preliminary issues, and identify interested and affected persons. The results of scoping are employed to clarify public involvement methods, refine issues, select an interdisciplinary EA review team, establish analysis criteria, and explore possible alternatives and their probable environmental effects. Moving towards these principal goals of scoping by circulation and/or publication of the current EA, Draft Environmental Assessment, Kaibab JV Exploration Drilling Program,

Tusayan Ranger District, Kaibab National Forest, Coconino County, Arizona, constitutes the early and open provision to potential cooperating agencies, and interested and affected persons, with descriptive material concerning the Proposed Plan of Operations. With these materials in hand, it is anticipated that cooperating agencies and other interested parties would be able to begin providing instructive feedback to the USFS while other preparations for the analysis of this Draft Environmental Assessment and its supporting documentation are being carried out by the USFS interdisciplinary review team. This particular strategy follows the spirit of the Council of Environmental Quality’s regulations concerning the task of reducing delay and hindrance in NEPA-related processes; for example:

§ 1500.2 Federal agencies shall to the fullest extent possible…(c) Integrate the requirements with other planning and environmental review procedures required by law or by agency practice so that all such procedures run concurrently rather than consecutively.


§ 1500.5 Agencies shall reduce delay by: (a) Integrating the NEPA process into early planning, (b) Emphasizing interagency cooperation before the environmental impact statement is prepared, rather than submission of adversary comments on a completed document. § 1501.2 Agencies shall integrate the NEPA process with other planning at the earliest possible time to insure that planning and decisions reflect environmental values, to avoid delays later in the process, and to head off potential conflicts.

Table III. Permits, Approvals, and Authorizing Actions Necessary for Execution of the Proposed Plan of Operations

Issuing Agencies Permit Name or Approval Nature of Permit/Approval Authority

USDA USFS Approval of Proposed Plan of Operations

Allows operations on federal lands

Federal Land Policy and Management Act of 1976 and 36 CFR 228

US Fish and Wildlife Service Arizona Game and Fish Department

Consultation Process, Endangered and Threatened Species

Biological assessment/biological opinion

Section 7 of the Endangered Species Act of 1973, as amended

Arizona State Historic Preservation Office

Concurrence Cultural resource protection Section 106 of the National Historic Preservation Act and Advisory Council Regulations

Arizona Department of Water Resources

Notice of Intention to Drill and Abandon an Exploration Well

Allows drilling of exploration drill holes in potentially aquifer-containing rocks in the State of Arizona

ARS 45 Waters, Article 10 Wells

Coconino County Department of Health

Concurrence with relevant provisions of Proposed Plan of Operations

Health regulations re: disposal of camp waste water.

ARS 36 Article 4 Local Health Departments

This list is intended to provide an overview of key regulatory requirements that would govern Proposed Plan implementation. Additional approvals, permits, and authorizing actions could be necessary.

Preliminary Summary of Issues and Concerns

The following preliminary list of issues and concerns relevant to the Proposed Plan of Operations has been gleaned from a review of recent (last two years) newspaper coverage concerning the matter of the return of uranium exploration and development in the Grand Canyon region, related legal suits, and the Canyon Mine Proposal Final Environmental Impact Statement (1986). Agency and private concerns raised to date relevant to the Proposed Plan of Operations include the questions:


1. What social and economic impacts would uranium exploration and development have on local communities and Coconino County?

2. What reclamation measures would be required during and after operations?

3. What impacts would uranium exploration and development activities have on

wildlife habitats, and the forest and grasslands vegetation?

4. What effect would mining-related activities have on the visual quality of the Kaibab National Forest, State Highway 64, and the Grand Canyon National Park?

5. What effect would exploration and mining activities have on the air quality of the

surrounding area?

6. What impacts would uranium exploration and mining activities have on the soils, and surface and subsurface water quality and quantity?

7. What impacts would uranium exploration and mining activities have on Indian

religious sites and practices?

8. What would be the impacts on the road system of the area during uranium exploration and mining activities?

9. What noise impacts would exploration and mining activities have on the Tusayan

Ranger District area? Among other things, the early agency and public scoping process initiated by the circulation and publication of this document is expected to augment and refine the above list.


Chapter 2. Proposed Action and Alternatives

Introduction

The purpose of this Chapter is to provide information on the Proposed Plan of Operations Alternative and the No Action Alternative.

Alternatives Analyzed in Detail

The No Action Alternative

Under this Alternative, the USFS would deny the Proposed Plan of Operations, and DIR Exploration, Inc., could continue non-drilling surface exploration work on the subject claims, surface exploration work recognized by the USFS to have no significant surface or other impact. Such exploration work does not require USFS approval under either a Notice of Intent or Plan of Operations (36 CFR 228.4).

The Proposed Plan of Operations Alternative

History and existing activities Each of the six (6) uranium prospects covered by the Proposed Plan of Operations has been explored by DIR Exploration, Inc., since the late 1980s. From 1987 through 1992, DIR acted as Operator of a joint venture between DIR and a Japanese government company, PNC Exploration (USA), Inc. During this joint venture, each of the prospects was examined through a combination of geological, geochemical, and geophysical studies. Following these exploration preparations, initial drilling exploration work approved by the USFS was conducted at the Bozo, Two-Squares, Grandpa, and Garfield Prospects. Follow-up surface exploration work on each of the prospects was carried out by DIR and the Kaibab JV in 2007 and 2008, employing an increased understanding of the geological attributes of uranium-mineralized collapse breccia pipes. The Proposed Plan of Operations would be guided by the geotechnical findings of both periods of uranium exploration carried out by DIR Exploration, Inc. General information

DIR would be carrying out the operations planned with the aid of one or more subcontractors. The operations detailed in this Plan have been approved by the Management Committee of the Kaibab Joint Venture in an Approved Program. Drilling contractors used would be Arizona-licensed, and a separate Plan of Operations for the


exploration drilling entailed by this Plan would be filed and approved by the Arizona Department of Water Resources before drilling operations are begun. This Plan of Operations envisions a maximum total number of forty (40) separate drill holes per year, an annual total that would be distributed over the six (6) different properties in a manner that reflects the emergent exploration drilling results. Because it typically takes 2 to 4 days to complete each drill hole, and Operator plans to employ only one drill rig at a time and for only one shift per day, drilling operations under this Proposed Plan of Operations are expected to last no more than eighty (80) to one hundred sixty (160) work days per year. The expected total duration of operations covered by this plan would be no more than three years on any given prospect after inception of operations on the prospect concerned. All drill sites drilled each year would be reclaimed by the calendar year end of each year of operations. The claims subject to this Proposed Plan of Operations are owned jointly by DIR Exploration, Inc., an Arizona Corporation, and Takara Resources, Inc., a Toronto Venture Exchange-listed public corporation. DIR and Takara cooperate under the terms of a joint venture agreement to carry out the business of the Kaibab Joint Venture. The address of the Kaibab Joint Venture is: Kaibab Joint Venture C/O DIR Exploration, Inc. 3614 G 4/10 Road Palisade, CO 81526 DIR is the sole Operator of this business joint venture and would be the sole Operator of the Proposed Plan of Operations. Description of proposed operations

A. Access: See Figure 5 for routes of access to each of the sites of operation. Existing open roads are represented as black lines. Cross-country (X-C) access routes are marked on this Figure. Maintenance work by Operator would be needed to improve the existing access route to the Maybe prospect but is limited to two sections, one 250 feet (0.05 miles) and one 1000 feet (0.2 miles) in length, and are marked on Figure 5 with short orange line segments. Improvements would be limited to minor rut filling, grading and tree-limbing along this Forest Service road 516. The vehicles that would utilize the access routes for this proposed operation are one to four light (1/2 ton) pick up trucks for daily personnel transport to and from drill sites, one ten-wheel truck mounted rotary/percussion drill rig7, and one ten-wheel water and supply trailer, one ten-

7 There would be a possibility that a reverse circulation drill rig with a down-hole hammer would be substituted for the rotary rig described. Such a rig has the same dimensions as a rotary rig and uses the same sort of circulation fluids (air and occasional water).


wheel water truck, one ten-wheel pipe truck and/or auxiliary compressor trailer and one crawler-type tractor or equivalent for reclamation. A road grader or small bull-dozer may be needed for the road rebuilding associated with the Maybe Prospect under this Proposed Plan. Figure 6 shows a typical water well type drilling rig.

B. Map: See Figure 5 again for the general location of the drilling areas at each

project; i.e., the area inside each claim block boundary marked with red rectangles. The drill pad at each drill hole site would be approximately 50 x 90 feet, including possibly associated drill cuttings and/or mud disposal pit.

C. Project Description: Operations would consist of a program of exploration

drilling on the claims, using a combination of rotary, percussion and core drill bits. It is anticipated that the four to seven inch diameter drill holes, with depths up to 2000 feet, would be drilled with air as the circulation fluid. However, “spot cores”8 and occasional intercepts of clayey lithologies might necessitate the infrequent use of water-based injection fluids. No more than 5000 gallons of water-based fluids would be injected in any given drill hole. Previous drilling experience in the Tusayan Ranger District by the Operator, as well as that documented by the Arizona Department of Water Resources and the USGS (2005), indicate that ground water is extremely unlikely to be found within the Proposed Plan area at the depths of drilling proposed; e.g., no water table was encountered in any of the 28 drill holes previously completed by Operator in the project area. Only biodegradable and non-toxic drilling fluid additives would be used if, during drill operations, water-saturated lithologies require the use of stabilizing additives in order to avoid loss of drill rod and bits.9 It is not anticipated that water diversion channels, or settling ponds would be needed due to the dry nature of the rocks in the proposed drill areas: Such ponds or channels were not used in completion of any of the 28 DIR drill holes previously completed within the Tusayan Ranger District.

8“Spot cores” are limited intervals of core, rather than percussion or rotary, drilling. Core drilling produces a cylindrical sample of rock which shows exactly how the rock appears in the subsurface. Cuttings produced by percussion or rotary drilling, on the other hand, yield only very small rock fragments that are only partially reflective of the nature of the subsurface rocks. 9 In cases where the rocks drilled are slightly damp, or in cases where some water is injected into the drill hole to permit use of a core bit, cuttings can temporarily stick to the drill hole walls and then collapse down around the drill rod and drill bit (“the drill string”). This makes continuation of the drill hole impossible until the rod and bit are removed from the drill hole, and the drill hole is cleaned out by re-drilling. In order to minimize the occurrence of such problems after placing or encountering some moisture in the drill hole, drillers inject a stabilizing foam along with air into the drill hole that helps stabilize the position of the drill cuttings caked along the surface of the drill hole.


Figure 5. Proposed Plan of Operations index and access map.


Figure 6. Late 1980s uranium exploration drilling at the Garfield Prospect.

Back end of water truck is shown on the far left. Truck in the middle is a combination water tank truck and pipe truck. Drill rig in the middle foreground.

Minimal drill site preparation would be required, as the drilling equipment that would be used can easily accommodate the gentle slopes present at each of the job sites. Rock cuttings would be disposed of in a pit dug adjacent to each drill site, except possibly in the case of the Garfield and Maybe Prospects, where – depending on actual drill hole collar locations – drill cuttings might have to be hauled off of the site in order to avoid the potential for affecting water quality in the tanks. Topsoil would be stockpiled away from rock cuttings and soil parent material for later use in the reclamation process in the unlikely event that water diversion channels or settling ponds were needed for completion of any given drill hole.

The planned drill sites would be located to avoid tree cutting and earth-moving, other than pit digging for rock cuttings and mud disposal, minor drill pad leveling, and possible minor tree trimming to avoid damage to both equipment and trees. All drill holes would be plugged with concrete after drill hole completion. Concrete caps of the drill holes would extend at least two feet into bedrock.


At any given prospect, this Plan of Operations would be carried out over a period extending no longer than three years following the beginning date of operations on that particular prospect. Drilling operations covered in the Plan will begin no sooner than May 1st of each year and close by the following December 1st, unless otherwise approved by an Authorized Officer of the Kaibab National Forest. Reclamation of the drill holes would be carried out annually, within each May-December field season and by or before the end of each calendar year. Operator-established cross-country access routes to and from the claims would be reclaimed upon completion of the Plan of Operations as it pertains to a given prospect, including any amendments, extensions, or replacements. Damage to open and closed roads by the Operator would be repaired as later described.

D. Equipment and Vehicles: The vehicles that would utilize access routes for this

Proposed Plan of Operations during each period of active drilling would be: One to four light (1/2 ton) pick up trucks for daily personnel transport to and from drill sites, one ten-wheel truck mounted rotary/percussion drill rig to access and leave each prospect during each drilling contract, one ten-wheel water truck to access the actively drilled prospect 0-2 times daily during each period of drilling, one ten-wheel pipe truck and/or auxiliary compressor trailer to access and leave each prospect during each period of active drilling, and one crawler type tractor or equivalent for reclamation to access each drilled prospect once per year.

E. Structures: If the Operator’s crew would be camping on or near the drill sites

during the operations of this Plan, the campsite would be placed within Operator claim areas previously cleared by the cultural resource survey. Structures used may include one to three pop-up tent or travel trailers, and one to three tents. Each camp kitchen area would have at least one type B, C dry chemical fire extinguisher, minimum capacity 2 and ½ pounds, visibly located in the immediate area of the kitchen, available for use at anytime. All such extinguishers would be checked annually for charge. All LP gas equipment used by the Operator would be installed and operated in accordance with the laws and regulations of the State of Arizona. All drilling-related temporary camp improvements would be removed before each December 1st end of the drilling field season, and the campsite area would be reclaimed at the time of the final Plan of Operations drilling reclamation work on a given prospect is carried out. Access to the campsite area would be materially blocked to easy access by passersby at the end of each field season. When Operator camps at a site within the claims subject to this Plan of Operations, Operator would, following the requirements of the Coconino County Department of Health, dispose of waste water in the following matter: Porta-potty, or equivalent, would be used for blackwater—the accumulated waste would


be disposed at an appropriate dump station; and gray water from kitchen and shower use would be disposed on-site within small disposal pits. Oil and other petroleum products used in the operations would be stored in approved containers away from drilling areas during operations so as to prevent environmental contamination. Operator would transport all garbage and trash resulting from operations to an Arizona/Country-approved sanitary landfill or other accepted waste disposal location.

Environmental protection measures

A. Air Quality: Not applicable. B. Water Quality:

1) Water use would only be needed during the drilling operations if saturated or clayey lithologies are encountered requiring the use of water-based injection fluids in order to minimize risk to the drill string. In any case, drinking water and water suitable for drilling purposes would be either obtained in Tusayan, Valle, Williams, Parks, or from local ranchers. Water would be stored in the drill water truck and/or small portable water storage containers. 2) In order to minimize erosion and surface runoff from disturbed areas, waste water and drill cuttings would be deposited in locations of very low slope to promote infiltration, and berms would be constructed if no such suitable locations exist. Drill cuttings that are more radioactive than surface background would be buried to a depth of at least three feet in such cases. 3) Low annual precipitation and karst topography have combined to prevent the accumulation of any bodies of permanent surface water in the area. However, in the event that ground water is encountered during the drilling, the affected aquifer would be sealed with a completion mud upon drill hole completion in order to prevent surface contamination of the underlying aquifer. The Operator would note depth and initial flow rate of the aquifer in any such cases, and this information would be sent to the Tusayan District Ranger and the office of the Arizona State Hydrologist before the end of each calendar year of operations. 4) During the annual cessation of operations, the annual reclamation process of covering affected areas with stockpiled topsoil and reseeded with a native seed mix would be used to minimize potential water quality impacts by preventing excessive runoff and erosion from the drill areas.


5) In the rare cases where recirculated10 drill water volume is too great to quickly infiltrate into the soil, this wastewater would be disposed in pits constructed on relatively flat slopes to prevent runoff and promote infiltration.

C. Solid Wastes: All trash and garbage would be hauled off site to an Arizona/County approved sanitation facility. As much as possible, drill cuttings would be returned to the borehole rather than be buried onsite during reclamation. A portable toilet would be made available for Operator and contractor use at all drill project sites.

D. Scenic Values: Annual reclamation processes as described below will reduce the

impact to scenery to the limited period of time when drilling is actually being conducted. Since no road building would be carried out under this plan, tree-cutting wastes would not be generated in quantities sufficient to necessitate mitigation. The planned use of a single drill rig run by a single contractor working a single shift, the usual 2-5 days to complete a drill hole, the wide distribution of the individual drilling projects, and the fact that the Proposed Plan worksites are located within strongly forested lands would all minimize impact on the scenic values of the general work area.

E. Fish and Wildlife: In keeping with aims of keeping wildlife habitat in a natural

state, surface impact would be minimized and restricted to drill pads and access roads and routes. Additionally, annual reclamation would restore affected areas as quickly and nearly as possible to natural conditions. Besides these habitat protective measures, scheduling of drilling work when and where required would avoid or minimize impact on the nesting and fledgling activities of northern goshawk. Restricting drilling work to daylight hours where sites are closely proximal to filled water tanks would minimize wildlife access to water sources. Populations of sensitive, rare plant species, made known to the Operator by the biological surveys supporting this Draft EA, would be protected from all surface disturbing activities by flagging and/or fencing. If, during exploration activities, an area of such vegetation is disturbed, the Operator would cease work in the affected area and promptly notify the Tusayan District Ranger. Work would not resume in the area concerned until Operator receives written approval by the Tusayan District Ranger. Since there is no permanent water near any of the planned drill areas, fish habitat would not be impacted.

10 In drilling, “recirculated” drill water is that water that descends through the drill pipe and bit, and then returns to the surface along the small space between the rock walls of the drill hole and the outside surface of the drill rods. Because the rock surrounding breccia pipes is heavily fractured and otherwise permeable, very little drilling fluid (including air) is typically returned to the surface after the first 300 to 500 feet of drilling.


Operator acknowledges that during periods of high or extreme fire danger it may be restricted or prevented by the National Forest Service from having open campfires, smoking, or gaining entry to the Kaibab National Forest. Before beginning planned operations, all internal combustion engines used in the operations would be inspected to ascertain that they are equipped with an approved spark arrestor and/or muffler system. Each vehicle or drilling rig used in the operations will be equipped with a fire extinguisher, bucket and shovel during operations. Open drill holes would be sufficiently blocked with fencing to prevent wildlife and livestock from stepping into the drill holes at anytime during operations. Hole cementing would be accomplished as soon as practicable after drill hole completion, and prior to full reclamation of the drill site concerned. No drilling under this Plan would take place any closer than 200 feet upslope of the high waterline of stock tanks present on a prospect without prior written approval of the Tusayan District Ranger. No drilling would take place within a quarter mile of a filled stock tank during nighttime hours. During use and prior to reclamation, any excavated mud pits greater than two feet deep will either be subjected to 24 hour/day surveillance, or fenced to a height of five feet, with the lowest fence strand being no higher than 14 inches above ground, and covered at the top with bird-proof netting. Fencing and netting used to surround mud pits would be removed upon reclamation.

F. Cultural Resources Clearance reports made on behalf of DIR have been previously filed with the

Forest Supervisor’s Office in Williams, Arizona. Results of resurveys requested by the Kaibab National Forest are summarized later in this report.

Any identified archeologically significant sites such as AR-03-07-04-820 on the extreme NW boundary of the Maybe Prospect would be flagged and/or fenced off, and would be purposefully and completely avoided during operations.

Archeologically sensitive locations on the prospects would be flagged with pink flagging at the start of operations at any given site. The meaning of pink flagging will be explained to contractors used by Operator before contractor operations begin, and this flagging would be removed annually at the conclusion of the work season’s operations.

Artifacts of cultural or scientific importance would not be injured, altered, destroyed, collected, or removed as a result of Operator’s work. During operations, if items of archeological or historical value are discovered, or a known deposit of such items is disturbed, Operator would cease work in the affected area and then notify the Tusayan District Ranger. Operations covered by this Plan


would not resume in the affected area until the Operator receives written approval for such work continuation from an Authorized Officer of the Kaibab National Forest.

G. Hazardous Substances: Not applicable. H. Reclamation: Each year, in reclamation of Operator-caused significant surface

disturbance, all new drill sites and top-soil covered drill cuttings and mud-containing pits would be treated, before seasonal termination of the Plan of Operations, to provide a proper seedbed to the seed mixture described below. The seeding would be done during or after seedbed preparation, which would consist of disking or ripping of the upper four inches of the disturbed surface being reclaimed. This same seedbed preparation procedure would be considered sufficient break-up of any vehicle compaction of access routes used in the operations. With the exception of three to five inch high mounds left above filled-in excavations to compensate for later settling, any Operator-created mounds or depressions in the operations areas would be smoothed to match original topographic contours. Topsoil would be conserved during any surface-disturbing activities involving excavation. Topsoil would be separately stockpiled and protected from other soil materials, soil parent material, and drill cutting until reclamation, during which the stockpiled topsoil would be applied last to cover the reclaimed disturbed area. All pits and other excavations would first be allowed to dry out before being backfilled. All roads which were closed prior to Operator’s use as access roads would be re-closed after end of this Plan of Operations, its amendments, extensions, or superceded replacements. If not already water-barred and drained, the re-closed road would be so protected where in excess of 25% grade. If requested by the Tusayan District Ranger, the re-closed road would be signed to the effect “not open to public vehicle use”. Any short cross-country drill site accesses that have become “roads” through heavy use would be reclaimed at the conclusion of operation as if they were constructed roads; i.e., they would be obliterated and reclaimed, and then posted with “not open to public vehicle use” signs provided by the Operator and left up until re-vegetation grasses are six inches high. At the end of each field season’s work, but prior to conclusion of work provided for by this Plan at any given prospect, cross-country access routes would be blocked and concealed at their beginnings with rocks and other native debris. Operator would repair at its expense all Forest Service Development Roads (FDR’s) and improvements to their original condition before Operator use if such roads and improvements are damaged by activities provided for in this Plan. Unless otherwise exempted, the Operator would comply with all Forest Service road closure orders.


On FDR’s shared with other Operators and users (e.g., ‘arterials’ down to ‘local terminal roads’), Operator would accomplish road maintenance and/or repair proportionate to its demonstrable share of use. At the least, this would consist of maintenance blading sufficient to repair Operator-created damage as referred to in the preceding paragraph and the paragraph following. When any road being used by the Operator would subjected by Operator to rutting deeper than three inches, or over-sized debris (such as tree limbs or rocks over three inches in diameter) would be deposited in the roadway, such hazards would either be promptly removed or the road would be posted as hazardous. In the event the sign posting is employed, the signing would cover travel in both directions and would indicate “unsuitable for passenger car use”. When signed, the road hazards would be removed as soon as is practicable. Excepting rights-of-way accorded to owners by mineral patent or other title-granting procedure, all rights-of-way would remain the property of the National Forest Service. The Operator’s use of any FDR would not be exclusive. All access routes (closed roads and cross-country accesses) which were not maintained by the NFS or any other legitimately operating entity (e.g., a rancher with a special use permit) prior to the Operator’s use as a deep drilling operations access routes, and all disturbed areas at drill sites, would be reclaimed by the Operator by seedbed preparation and planting to the following formula, or other seed mix approved by the Kaibab National Forest: Fairway Crested Wheatgrass 5 lbs. /acre Intermediate or Western Wheatgrass 5 lbs. /acre Yellow Sweetclover 2 lbs. /acre Total seeding rate 12lbs. /acre

Bond

The Operator would furnish to the Authorized Officer of the Kaibab National Forest a reclamation performance bond or equivalent prior to the beginning of the planned operations at any given prospect. The amount of the bond or its equivalent would be determined by the Tusayan District Ranger’s Office prior to the Forest Service approval of this Plan of Operations, and would be sent to DIR in writing immediately after such determination.


Chapter 3. Affected Environment The purpose of this chapter is to provide a baseline view of the environment that would be affected by the Proposed Plan of Operations. The Environmental Assessment,

Tusayan Wildlife Waters Project found at http://www.fs.fed.us/r3/kai/projects/ (2008) describes in much more detail the current, general natural, cultural, and geographic setting of the Proposed Plan of Operations and the Tusayan Ranger District. Chapter 4 discusses in more detail those aspects of the environment that would be directly or indirectly affected by the Proposed Plan of Operations.

Regional Setting and Land Use

Introduction

The Proposed Plan of Operations would, if approved, take place in the 331,427 acre (518 square mile) Tusayan Ranger District of the Kaibab National Forest on lode mining claims located in the southern portion of the District, southeast, east, northeast, north, and northwest of Red Butte. The Tusayan Ranger District marginates the south rim portion of the Grand Canyon National Park, and is neighbored to the west by the Hualapai Reservation and private and State Trust lands, on the east by the Navajo Nation, and on the south by private and State land holdings. The nearest city of Flagstaff, Arizona (2007 population estimate, 127,000+), is approximately 75 road miles from the center of the Proposed Plan of Operations. The tourist town of Tusayan is a small (560+ population, 2000 census), privately-owned inholding within the Tusayan Ranger District located on Highway 64, and is approximately 15 road miles from the center of the Proposed Plan of Operations. A much less developed and much smaller tourist town, Valle, lies about the same distance south-southwest of the Proposed Plan of Operations center within the checkerboard of State and private lands. The town of Williams (2006 population, 3000+) is 30 miles due south of Valle, and 30 miles due west of Flagstaff. The prospects concerned by the Proposed Plan of Operations fall within two separate Ecosystem Management Areas (“EMA’s”), as summarized below. See Figure 5 above for the location of each prospect that would be drilled within the two EMA’s if the Proposed Plan of Operations is approved.

Southern Tusayan Woodland (EMA 8)

EMA 8 (Ecosystem Management Area 8), as specifically described in the amended Kaibab National Forest Management Plan (http://www.fs.fed.us/r3/kai/plan-revision/forestplan.shtml), is referred to in that Plan as the Southern Tusayan Woodland, which is located on the Coconino Plateau with elevations ranging from 6200 to 6700 feet. This tree, sagebrush, and grass-covered plateau is dissected by an incised south-trending drainage system subject to ephemeral water flow resulting from an average annual precipitation of about 16 inches. The Southern Tusayan Woodland is dominated by pinyon pine, Utah juniper, and big sagebrush. Understory shrubbery in the lower


elevation pinyon-juniper-sagebrush parts of the Woodland include occurrences of the sensitive plant species, Chrysothamnus molestus (Tusayan Rabbitbrush). A smaller, higher-elevation portion of the Woodland is coniferous with mixed ponderosa pine, pinyon pine, Utah juniper, and rare and isolated Gambel oak and Big sagebrush occurrences. In addition to rabbitbrush, forage species in the Southern Tusayan Woodland include blue gramma, mutton bluegrass, squirreltail, and junegrass. Attendant management indicator species for EMA 8, where and when present, are mule deer, elk, pronghorn antelope, turkey, hairy woodpecker, northern goshawk, and plain titmouse. EMA 8 is winter habitat for deer, turkey, and pronghorn antelope. Historically, the same area functioned as a winter use area of the Havasupai. Grasslands interspersed within the Woodland are currently foraged by cattle and horses, with about 60% of the grassland being in balance with grazing capacity. Excessive grazing and associated soil compaction take place in proximity to the few livestock and wildlife water sources scattered over the EMA. Fuel load in EMA 8 being relatively low, high intensity fires are unlikely and most fires occurring in the Woodland are therefore more beneficial than harmful to the landscape. Cultural resource site density in EMA 8, judging by very limited inventory work, is generally high. EMA 8 of the Tusayan Ranger District contains the viewscape-sensitive travel routes of Highway 64 and the Arizona Trail, as well as the scenic and historic features of Red Butte and Moqui Stage Station, respectively. A major E-W powerline crosses the southern portion of EMA-8.

Tusayan Forestland (EMA 10)

EMA 10 (Ecosystem Management Area 8), as specifically described in the amended Kaibab National Forest Management Plan, is referred to in that Plan as the Tusayan Forestland, which is located in the central section of the District with elevations ranging from 6700 to 6900 feet. This higher portion of the Coconino Plateau is also dissected by an incised southwesterly-trending drainage system subject to ephemeral water flow resulting from an average annual precipitation of 18 inches. The Tusayan Forestland is dominated by ponderosa pine with scattered understory Gambel oak. Secondary pinyon pine and Utah juniper are generally found at the lower and/or more xeric portions of this EMA. Predominant forage species in the Forestland are big sagebrush, snakeweed, blue grama, mutton bluegrass, mountain muhly, and junegrass. Relatively isolated occurrences of the category two sensitive shrub, Tusayan Rabbitbrush, are known to occur in this portion of the Forest. The principal elk calving, mule deer, and pronghorn antelope fawning, and turkey nesting habitats of the Tusayan Ranger District are located in this EMA. Management indicator species using this EMA are elk, turkey, mule deer, pronghorn antelope, northern goshawk, pygmy nuthatch, hairy woodpecker, and plain titmouse.


As in the case of the Southern Tusayan Woodland, the Tusayan Forestland is typically grazed by cattle from spring through fall, with much of EMA10 being, once again, out of balance with grazing capacity because of livestock and wild ruminants congregating around the limited water sources of the area. Fuel load in EMA 10 is variable, with some areas containing high hazard load and others very sparse, low hazard fuel loads. EMA 10 contains high densities of heritage resources. Those that have been inventoried have yet to be evaluated in sufficient detail for final disposition, however. The Hull Cabin Historic District and the Grandview Lookout Tower/Cabin at the northeast end of EMA 10 are listed in the National Register of Historic Places. EMA 10 of the Tusayan Ranger District, like EMA8, also contains part of the viewscape-sensitive travel route of the Arizona Trail.

Existing and Foreseeable Land Uses

According to Environmental Assessment, Tusayan Wildlife Waters Project found at http://www.fs.fed.us/r3/kai/projects/ (2008), the multiple use National Forest system lands concerned by the Proposed Plan of Operations are primarily managed for cattle grazing, timber and commercial fuelwood harvesting, wildlife management, mineral exploration and mining, and the direct public uses of hunting, firewood gathering, and Christmas tree cutting. Recreational use of the Tusayan Ranger District is largely related to public visitation to the Grand Canyon National Park, particularly by way of the use of State Highway 64, overnight camping at the USFS-operated Ten-X campground, and limited special use permits for jeep, ATV, and horse tours in the Tusayan area. The USFS is itself involved in a number of ongoing land and wildlife management projects on the 331,427 acre (518 square mile) Tusayan Ranger District. These projects are listed in Table IV below (USFS 2008). Projects that result in significant permanent surface disturbance are highlighted in yellow.

Geology, Pedology, and Hydrology

Geology

The Tusayan Ranger District lies on the southwestern side of the Colorado Plateau. The Colorado Plateau is a relatively stable area of flat-lying Paleozoic and Mesozoic sedimentary rocks. Figure 2 above illustrates the generalized stratigraphic section of the Grand Canyon and Tusayan Ranger District area. The east-west trending Grand Canyon exposes rocks of the Precambrian (~1800 million years ago) through the Permian (~275 million years ago). In the Tusayan Ranger District area, about four thousand feet of nearly horizontal Paleozoic sandstones, shales-siltstones, and carbonates, lie atop the Cambrian Tonto sandstone-mudstone-limestone Group, which, in turn, was deposited upon a Precambrian basement of schists, granites, and sedimentary rocks. At extremely


Table IV. Ongoing USFS Projects with Significant Surface Impact

Activity Project Name Time Range

Area of Influence

Livestock and wildlife water development

Various 1880s to present for livestock, 1960s to present for wildlife

District-wide

Grassland maintenance

Harbison, Nameless, No-Name, O’Connell, Moqui

2002-2010 4,500 acres

Prescribed burning Various Ongoing District-wide

Fuels reduction Lone Tree, Topeka, Long Jim, Tusayan South, Tusayan West, Tusayan East, Boggy Tank

1996 to present

USFS lands adjacent to Tusayan and the GCNP

Non-commercial tree thinning

Various Ongoing District-wide

Fence modification Pronghorn antelope fence modification

Ongoing 33 linear miles

Trail construction and reconstruction

Arizona Trail, Greenway Trail, Red Butte Trail, miscellaneous bicycle trails

Ongoing District-wide

Noxious Weeds Noxious Weed Control Ongoing District-wide

Tusayan District Motorized Travel Management

Tusayan Travel Management Rule Draft Environmental Analysis

2008-2009 District-wide

Fuels Reduction Airport WUI 2008-2014 3,000 acres

Cell Tower Construction

Highway 64/180 Wireless Communication Sites

2008-2011 2 sites on Highway 64/180 corridor

Energy Corridor Construction

Federal land in 11 Western States

2008-2015 Southern portion of Tusayan RD

Grand Canyon Transportation Plan

South Rim Visitor Transportation Plan (EA)

2008-2012 10 USFS acres

Highway 64 Reconstruction

ADOT widening of Highway 64 to 4 lanes from Williams to Tusayan

2008-2013 11 road miles through Tusayan RD: Approx. 1300 acres.

rare sites within the Tusayan Ranger District (e.g. Red Butte), Triassic Shinarump Conglomerate and underlying Moenkopi Formation (red bed sandstone) overlie the Permian Kaibab Formation (siltstones, sandstones, limestones, and dolomites). Only at a very few locales within the Tusayan Ranger District does the Triassic Moenkopi Formation – rather than the Permian Kaibab Formation – exist as the topmost sedimentary rock exposed to the surface.


Previous DIR drilling (DIR 1993) on the prospects covered by this Proposed Plan of Operations shows that the Kaibab Formation ranges from 220 to 310 feet thickness, the Toroweap Formation beneath (with rocks generally like those of the Kaibab) to be some 320 to 345 feet thick, and the Coconino Sandstone (a clean eolian sandstone) to be from 580 to 690 feet in thickness. The Hermit Formation, a muddy, very fine-grained sandstone found directly below the Coconino Sandstone, ranges from 140 to more than 200 feet thickness in the Proposed Plan of Operations work area. The bulk of known breccia pipe mineralization is found within the Hermit Formation and the basal unit of the Permian stratigraphic section, the Esplanade Sandstone of the Supai Group. The Esplanade Sandstone is 200 to 400 feet thick in the Tusayan Ranger District area. The Kaibab Formation’s uppermost Harrisburg Member, maximum thickness of about 120 feet, is the dominant outcrop on the prospects covered by the Proposed Plan of Operations. During the Triassic through Late Cretaceous-Eocene series of mountain-building orogenies, all of northwestern Arizona was compressed from directions ranging from the northwest to southwest, and uplifted. Thereafter, release of compression resulted in fault-breaking of the uplifts and provided the final structural elements for the present regional topography of small secondary plateaus (Kanab, Coconino, Kaibab, Paria, and Shivwits Plateaus) within the southwest end of the primary Colorado Plateau. The Proposed Plan of Operations area and the Tusayan Ranger District are located on the gently southwest-dipping (1-3 degrees) Coconino Plateau. The Canyon Mine EIS (1986, pp. 3.4-3.5) reports that the Tusayan Ranger District is sufficiently seismically stable for buildings and most other construction activities.

Pedology (Soils)

Local landforms in the Proposed Plan of Operations area include nearly level to gently sloping drainage bottoms of recent alluvium, nearly level to gently sloping ridge tops, and gently to moderately sloping drainage walls (0%–15% slopes overall). Soils have developed from residual and/or colluvial parent materials on this slightly to moderately-incised plateau topography. Kaibab Formation rocks are widely exposed through the shallow soils of the ridge tops and ridge sides. Soils range from bedrock limestone outcrops to broken up bedrock on the ridge tops and ridge sides, to organic loam to fine alluvium, usually on topographic lows. Pebbles and rock chips of chert and limestone also occur. Broken up bedrock, pebbles and rock chips often occur as tight veneer (desert pavement) over finer-grained, clay soils or as scattered fragments the soils. Finer soils range from medium to fine grained tan to reddish brown silts, sands, and clays. Forest duff layers occasionally cover soils and bedrock. The level to moderately-sloping plains with gradual, rolling hills and small drainages are at some risk for sheet and rill erosion (capable of eroding at rates greater than the long-term sustainable level). In order to minimize incidence of soil erosion, precautions


should be taken to minimize the creation of new bare soil areas on the proposed project areas. The vegetative cover over a slightly to moderately-incised limestone terrain that varies both locally and regionally from forestland to grassland in a cool, semi-arid climate resulted in a soil cover varying from (USFS 2008) dominant, relatively thin weakly to moderately developed Inceptisols11 to less prevalent (second most common), but more mature and more fertile Alfisols12. At ridge tops and other areas particularly subject to chemical and physical weathering, very thin, immature Entisols13 occur. Rare, grass-covered soils occurring in narrow strips along the sides of some of the Ranger District’s drainages have developed into thick, cool-climate Mollisols especially supportive of vegetation.14 The dominant Inceptisols of the area are found on the relatively dry and warm south-facing slopes, while the less common Alfisols are located on wetter north-facing slopes of Skinner Ridge and the Coconino Rim, and in rare areas where the parent rock material like Moenkopi and Kaibab Formation red beds better support the formation of soil clays. The influences of parent material, climate, slope, and vegetation have resulted in 46 unique terrestrial ecosystem survey (TES) map units within the Tusayan RD (USFS 1991). TES map units that are typically associated with the pinyon-juniper, sagebrush, and fourwing saltbush ecosystems in the upland sites (outside of drainage bottoms) generally have high calcium carbonate contents, have shallow to moderately deep soil depths (10–40 inches of soil material), and contain a high concentration of rock fragments on the soil surface and in the profile. Soils in the ponderosa pine ecosystem tend to have more clay content, which contributes to greater runoff and an inherently higher productivity potential. Like those units found in the pinyon-juniper woodlands, the rock fragment content is considerably higher on the upland sites, in contrast to the alluvial bottoms, where loam textures and deep soils are more prevalent. Where grassland ecosystems predominate, the soils are deep to very deep, medium- to fine-textured, and relatively free of rock fragments. Table V lists the specific soil types present at the sites covered by the Proposed Plan of Operations according to the Terrestrial Ecosystem Survey (USFS 1991) of the Tusayan Ranger District and field observations.

11 Soil order with well-developed uppermost organic-rich A-layer but poorly-developed, underlying clay-rich B-layer. 12 Soil order with well-developed organic-rich A-horizon and moderately well-developed clay-rich B-horizon. Content of calcium, potassium, magnesium, and sodium is less than that of Mollisols. 13 Soil-forming processes have had little effect on these soils, so that only a weakly-developed surface horizon is present. There may be salt accumulations at depth, however. 14 Soil order with high content of organic matter in the upper A-horizon and with high base (calcium, potassium, sodium, magnesium) content throughout the soil profile.


Table V. Proposed Plan Project Area Soils

Prospect Soil Code(s) Suborder(s) Management Indications Bozo 80% 275,

20% 265 Lithic Ustochrepts Possible shallow depths & high

rock content of soils, and slopes will limit mechanical treatment. Caution should be taken so the subsoil is not brought to the surface due to its high pH.

Garfield 100% 275 Lithic Ustochrepts As above.

Grandpa 100% 287 Lithic Ustochrepts As above.

Maybe 40% 275 60% 283

Lithic Ustochrept, Typic Eutroboralf

As above for the Inceptisol, while the Alfisol has low bearing strength when wet. Operations that mix clayey subsoil with the surface horizon will reduce site productivity and the probability of success for re-vegetation.

Sze 20% 260 80% 275

Lithic Ustochrepts See Inceptisol management indications provided above.

Two-Squares 75% 260 25% 283

Lithic Ustochrepts As above.

Watershed, Subsurface Hydrology, and Hydrogeochemistry

Watershed Speaking specifically of the operations area of the Proposed Plan of Operations, there is no permanent surface water on any of the land area covered by the Proposed Plan of Operations. Ephemeral drainages occur within the project area or along the access roads of all six Plan operation sites. Man-made tanks occur at the Garfield (Gregg Tank) and Maybe (Maybe Tank) prospects. The Proposed Plan of Operations are located west of the Coconino Rim, and ephemeral water run off flows into Red Horse Wash, a component of the Heather Wash fifth code watershed. Heather Wash flows into Cataract Creek, which flows into the Colorado River in the Grand Canyon. No riparian or wetland vegetation is located within the project vicinity. Surface water flow events are classified as ephemeral (USFS 1991), occurring in response to snowmelt or runoff from heavy rains. The only semi-reliable water in the area is found in earthen stock tanks, wildlife catchments, or roadside tanks that catch and hold rainfall and snowmelt. However, even these water sources can dry up during drought conditions. According to the Terrestrial Ecosystem Survey (USFS 1991), erosion rates in the projects area of the Proposed Plan of Operations were within the sustainable range as of 1989. Field visits to the site in November 2008 by William Liebfried Environmental Services confirmed that erosion rates are not excessive. Soil types within the prospects covered by the Proposed Plan of Operations are largely at shallow to moderately deep, fine-textured alluvium with admixed scattered limestone, sandstone, and chert pebbles, material which


contributes to a high percolation rate and minimizes runoff, especially in the pinyon pine, sagebrush, and saltbush terrestrial ecosystems (ibid.). The projects area is not part of any municipal watershed or other domestic water supply. There are no impaired waters listed by the Arizona Department of Environmental Quality (ADEQ) on the Tusayan RD (ADEQ 2004, 2006). KNF does not regularly monitor water quality and has no recent water quality monitoring data. Subsurface hydrology The following summarizes hydrological observations provided in Hydrogeology of the

Coconino Plateau and Adjacent Areas, Coconino and Yavapai Counties, Arizona, by the United States Geological Survey (“USGS”) in cooperation with the Arizona Department of Water Resources (2005)15, Grand Canyon Springs and the Redwall-Muav Aquifer:

Comparison of Geologic Framework and Groundwater Flow Models (Kessler 2002),16 Hydrology of Glen Canyon and the Grand Canyon (Dawdy 1991),17 and Sediment

Transport in the Colorado River Basin (Andrews 1991).18 In the Tusayan Ranger District area, the only water-saturated aquifer occurs in the deep Redwall-Muav stratigraphic level, with water table top ranging in elevation from 4200 feet down to 3500 feet. See Figure 7. Direction of water flow within this aquifer in the Tusayan Ranger District is indicated on Figure 7 by large blue arrows. Aquifer water flow in the area concerning the Proposed Plan of Operations is southwesterly, away from the Colorado River and the Grand Canyon. Redwall-Muav aquifer waters originating from ground water recharge in the Proposed Plan of Operations area exit to the surface in springs feeding Havasu Creek (which flows northerly), and make up part of the 98% of the Redwall-Muav aquifer leakage entering the Colorado River through Havasu Creek and the Little Colorado River (Kessler 2002). The numerous, much lower flow South Rim springs -- the alternative outlets for Redwall-Muav aquifer ground water -- within the Grand Canyon National Park compose, in the aggregate, only 2% or so of the Redwall-Muav aquifer contribution to the Colorado River waters (ibid.). According to the USGS, “All of the ground water in the Redwall-Muav aquifer is the result of downward leakage from overlying [rock] units through faults, fractures, or other geologic structures, such as breccia pipes” (Mills et al., 2005, p. 41). Potential ground water contamination related to mined and/or undeveloped uranium-mineralized collapse breccia pipes therefore would occur from downward movement of ground water into the Redwall-Muav aquifer along vertical structures like those enumerated by the USGS.

15 http://pubs.usgs.gov/sir/2005/5222/ 16 http://www.cefns.nau.edu/Academic/Geology/programs/MS-geology/Theses/CompletedMSTheses.shtml#year_2008 17 Pages 40-53 from Colorado River Ecology and Dam Management Proceedings of a Symposium May 24-25, 1990 Santa Fe, New Mexico (1991) available online at http://www.nap.edu/openbook.php?record_id=1832. 18 Pages 54-74 from Colorado River Ecology and Dam Management Proceedings of a Symposium May 24-25, 1990 Santa Fe, New Mexico (1991) available online at http://www.nap.edu/openbook.php?record_id=1832 .


Given the very high average annual evaporation rate in this semi-arid region, most of this downward recharge to the Redwall-Muav aquifer is believed to be derived from unevaporated and unsublimated precipitation sinking down into the earth during the coolest times of the year. Approximately 60% of the annual precipitation falling upon

Figure 7. Map showing direction of Redwall-Muav aquifer ground water flow in the Tusayan Ranger District area.

Black squares represent locations of the six (6) drilling projects covered by the Proposed Plan of Operations. The blue contour lines represent elevation of the top of the aquifer, with ground water flow moving from high elevation to low elevation. Blue arrows indicate the consequent flow directions. Ground water moves southwesterly, away from the Colorado River, and then turns northeasterly towards Havasu Creek. Water table surface elevation map is from USGS Scientific Investigations Report 2005-5222.

the region occurs during the winter (Mills et al., 2005, p. 16): Isotopic data from springs, streams, and wells on the Coconino Plateau show that the aquifer waters throughout this semi-arid region are, in fact, most similar to the composition of water from winter precipitation (ibid., p.53). Metzger (1961)19 has calculated that the aquifer recharge rate for the Proposed Plan of Operations region varies narrowly from 0.1 to 0.3 inch/year.

19 http://pubs.er.usgs.gov/usgspubs/wsp/wsp1475C


Due to the construction of Glen Canyon Dam and Hoover Dam, Colorado River water flow rates and sediment load are not only determined by seasonal and long-run precipitation, precipitation run-off, and evaporation patterns in the upper and lower Colorado River Basin, but also are determined by human decisions controlling reservoir water releases. While most of the annual water discharge into the Colorado River basin is sourced in the Rocky Mountain headwaters, the bulk of the sediment carried by the river is obtained from surface run-off from the river’s tributaries in the semiarid areas of the Colorado River basin in southeastern Utah, northern Arizona, and northwestern New Mexico. According to Andrews (1991), Rocky Mountain headwater tributaries contribute more than 75% of the total water discharge passing through the Grand Canyon, but only 31% of the sediment load carried by that water. Maximum sediment loading of Colorado River water occurs during the July through September monsoon season impacting semiarid Colorado River tributary drainages like the Paria River and the Little Colorado River. Maximum water discharge into Lake Powell from the Rocky Mountain headwaters of the Colorado River, on the other hand, occurs during the April through July Rocky Mountain snowmelt period (Figure 4-3, Andrews 1991). Because Glen Canyon Dam is located downstream of significant portions of the sediment-contributing, semiarid part of the Colorado River basin, a large amount of sediment is trapped in Lake Powell. Nonetheless, approximately 11-12 million tons of sediment per year are supplied to the Colorado River by the Paria River and Little Colorado River. Both of these Colorado River tributaries are downstream of Glen Canyon Dam yet upstream of the Grand Canyon. Uncontrolled water flows and sediment loads passing through the Grand Canyon are both sourced largely from these two tributaries to the Colorado River. Metals hydrogeochemistry Hydrogeochemical data provided here were published by the USGS as Chemical

Characteristics of Ground-Water Discharge along the South Rim of Grand Canyon in

Grand Canyon National Park, Arizona, 2000-2001 (2004)20, Data from Synoptic Water-

Quality Studies on the Colorado River in the Grand Canyon, Arizona, November1990

and June 1991 (1996)21, and as Concentrations and Annual Fluxes for Selected Water-

quality Constituents from the USGS National Stream Quality Accounting Network

(NASQAN) 1996-2000 (2001).22 These studies provide baseline water quality measurements of both the Colorado River in the Grand Canyon region and the Redwall-Muav aquifer waters potentially affected by uranium exploration and mining operations south of the Grand Canyon. It is important to keep in mind that the Redwall-Muav aquifer is drained into the Colorado River on the north by the South Rim springs and creeks (2% of the Redwall-Muav aquifer leakage to surface), and on the northwest and the northeast by the Havasu Creek and the Little Colorado River, respectively (98% of the Redwall-Muav aquifer leakage to the surface).

20 http://pubs.usgs.gov/sir/2004/5146/ 21 http://pubs.er.usgs.gov/usgspubs/ofr/ofr96614 22 http://pubs.er.usgs.gov/usgspubs/wri/wri014255


Following the USGS (Taylor et al, 1996; Monroe et al., 2004) findings that only dissolved arsenic, uranium, and alpha particle radioactivity of the springs, seeps, and creeks draining the area containing the Proposed Plan of Operations are potentially problematic as far as drinking water quality is concerned, only the regional hydrogeochemistry of these solutes23 is examined here in detail. Metals hydrogeochemistry of the Colorado River

The range of annual dissolved trace metals load

24 and concentration25 of uranium and

arsenic carried by the Colorado River through the Grand Canyon region is illustrated in Figures 8, 9, 10, and 11. The dissolved trace metals load and concentration of several other elements known to be also associated with uranium-mineralized breccia pipes – molybdenum, zinc, and lead – are also provided in Figure 10. These water metals concentrations of the Colorado River are comparable, on an order of magnitude basis, to those of average freshwater (Table VI), and those of other US major rivers (Figures 8 and 9). However, according to the information provided in Table VI, Colorado River water contains lower than average amounts of arsenic, lead, and zinc, than average freshwater, and higher than average amounts of molybdenum. The average amount of uranium

dissolved in Colorado River water (4.6 ppb) is slightly lower than the average amount

expected in freshwater flowing through an arid terrain (5.0 ppb). Note that these low levels of dissolved uranium are not normally associated with potentially harmful concentrations of gross-alpha radioactivity in Grand Canyon region ground water (Figure 14). According to the USGS (ibid. 1996) Colorado River water data, annual flux of dissolved uranium passing through the Grand Canyon ranges from a rate of about 20,000 kg (44,000 pounds) of uranium per year (November 1990 low river flow rate) to 100,000 kg (221,000 pounds) uranium per year (June 1991 high river flow rate). Figures 11 and 12 show November 1990 and June 1991 averaged uranium and arsenic loads of the Colorado River in map view. These two maps show that both elements largely fall out of solution upon entry into Lake Mead, thereby decreasing the dissolved arsenic and uranium concentrations further below the average freshwater dissolved metal values shown in Table VI. Presumably, the flatter riverbed gradients of the Colorado River at the entry to Lake Mead permit settling of the metals to the lake bottom along with metal-absorptive silt, clays, and organic matter.

23 Substances dissolved in water. 24 “Load” in this case refers to the mass of a metal or other constituent held in solution and transported by the Colorado River and is expressed as kilograms (kg)/year. 25 “Concentrations” in this case refers to the level of a metal or other constituent (solute) held in solution by the Colorado River and is expressed as parts per billion. Given the limited amount of water that humans drink each day, it is the concentration of a metal or other solute in drinking water that ultimately determines whether that constituent will be ingested in amounts that will be harmful to the person drinking it. Higher concentrations of a metal or compound in drinking water increase the probability that a metal or compound in that water will harm the person drinking it.


Table VI. Colorado River Dissolved Trace Metals in Context

All metals concentration values in parts per billion. Freshwater and crustal averages from Geochemistry in Mineral Exploration, 2nd edition, by Rose et al., 1979. Colorado River water averages are from USGS OFR 96-614 (Taylor et al., 1996).

Trace Metal Colorado River

Average

Freshwater Average

Average Crustal Rock

Arsenic 1.8 2.0 2,000

Molybdenum 4.6 1.5 1,500

Lead 0.5 3.0 10,000

Uranium 4.6 5.0 (arid region)

0.5 (humid region)

2,500

Zinc 1.5 20.0 80,000

Figure 8. Dissolved uranium of Colorado River in context.

From Kelley et al., 2001.


Figure 9. Dissolved arsenic of Colorado River in context.

From Kelley et al., 2001.

Metals hydrogeochemistry of the South Rim springs and creeks Monroe et al. (2004) of the USGS sampled and analyzed springs and creeks on the South Rim of the Grand Canyon for dissolved concentrations of the following forty-eight (48) constituents: Aluminum, antimony, arsenic, barium, beryllium, bismuth, boron, bromide, cadmium, cerium, chromium, cobalt, copper, dysprosium, erbium, europium, gadolinium, holmium, iron, lanthanum lead, lithium, lutetium, manganese, mercury, molybdenum, neodymium, nickel, praseodymium, rhenium, rubidium, samarium, selenium, strontium, tellurium, terbium, thallium, thorium, thulium, tungsten, uranium, vanadium, ytterbium, yttrium, zinc, zirconium, and gross-beta and gross-alpha radioactivity. Of these various solutes, the USGS determined that the concentrations of twelve (12) merited mention and attention as far as the water quality standards of springs and creeks along the South Rim are concerned. Table 7 of Monroe et al. (2004, p.23) is reproduced here as Figure 13 and summarizes nearly all of the South Rim spring and creek water quality observations of USGS. Of the twelve solutes given attention by the USGS in Table 7 of Monroe et al., 2004 (Figure 13, again), only water concentrations arsenic and uranium were found to locally exceed EPA recommended Maximum Contamination Levels (“MCL”, 2003). Not mentioned in this reproduced Table is the 22.0 pCi/L gross-alpha radioactivity determination by USGS (ibid., 2004, Table 8, p. 54) for Salt Creek Spring. This value is 7 pCi/L more than the EPA Maximum Contaminant Level (MCL) of 15 pCi/L for gross-α radioactivity. Potential effect of alpha radiation in drinking water is increased risk for cancer (EPA 2003). The spring and creek data for the region, as well as chemical theory (ibid.), do support a close causal relationship between ground water


uranium concentrations and gross-alpha radioactivity levels of those waters: See Figure 14 which indicates that only waters containing more than 30 ppb uranium (the EPA MCL for dissolved uranium) in the region are likely to evidence potentially harmful levels of gross-alpha radioactivity. None of the South Rim springs and creeks in the 2004 USGS water quality study evidences levels of gross-beta radioactivity potentially harmful to human health. Figure 15 shows the locations of the South Rim springs and creeks sampled and analyzed by Monroe et al., 2004. Table VII provides the average dissolved arsenic and uranium concentrations and annual output of these metals from these springs and creeks. Figure

15 indicates that only elevated dissolved uranium values, and not those of arsenic, are

associated with the economically-mineralized collapse breccia pipe found at the Orphan

Mine.

Metals hydrogeochemistry of Havasu Creek and Little Colorado River Values of trace metals associated with the Havasu Creek and Little Colorado River spring-fed release of Redwall-Muav aquifer ground water to the Colorado River were determined by Taylor et al., 1996, in Data from Synoptic Water-Quality Studies on the

Colorado River in the Grand Canyon, Arizona, November 1990 and June 1991. Although this report provides no direct analyses of the springs found in the lower Little Colorado River, influence of the Redwall-Muav aquifer springs in this part of the Little Colorado River is included in the Taylor et al., 1996, water quality values for the mouth of the Little Colorado. Blue Springs in the lower Little Colorado River issuing from the Redwall portion of the Redwall-Muav aquifer provides the base perennial flow of the Little Colorado River. This USGS work showed that for Havasu Creek, arsenic was the only trace metal exceeding that metal’s EPA MCL for drinking water of 10 ppb. Arsenic determinations for Havasu Creek waters taken just upstream of its junction with the Colorado River showed a November 1990 average concentration of 11.7 ppb arsenic and a June 1991 level of 11.1 ppb arsenic. Havasu Creek dissolved uranium concentrations during this study ranged from 3.73 to 3.77 ppb uranium, well below the EPA MCL of 30 ppb. Although the synoptic study completed by the USGS in Taylor et al., 1996, did not determine gross-alpha radioactivity of the Redwall-Muav aquifer waters contained in Havasu Creek, the low level of uranium concentration in this water indicates that the gross-alpha radioactivity of the water is very likely below the EPA MCL for this solute (see Figure 14 again). Neither arsenic nor uranium concentrations are above the EPA MCL in the Little Colorado River. Table VIII provides concentration and annual metal releases for both Havasu Creek and the Little Colorado.


Figure 10. Dissolved metal loads and concentrations, Colorado River.

Data from Taylor et al., 1996.


Figure 11. Colorado River dissolved arsenic.

Figure 12. Colorado River dissolved uranium.

Both Figures show annual dissolved metal load as determined by averaging flow rates and metal concentrations for the two separate periods of sampling (November 1990 and June 1991) in the synoptic water sampling program reported in USGS Open-File Report 96-614, by Taylor et al,, 1996. Size of

colored circles is proportional to annual metal load.


Figure 13. Table 7 of Monroe et al. (2004).


Figure 14. Evidence of causal relationship between dissolved uranium content and water gross alpha-radioactivity.


Figure 15. Locations of south rim springs and creeks studied by USGS.


Table VII. South Rim Springs and Creeks

Averaged Concentration and Release Data from USGS SIR 2004-5146

Sampling Site Concentration Concentration Arsenic release Uranium release

ppb arsenic ppb uranium grams/year grams/year

Red Canyon Spring 17 1.7 103 10.3

JT Spring 9.45 3.8 9.93 3.99

Miners Spring 18.3 3.3 19.6 3.53

Cottonwood Creek #1 1.2 1.5 1.96 2.44

Cottonwood Creek #2 4.75 1.6 42.4 14.3

Grapevine Main Spring 5.35 1.1 20.7 4.25

Grapevine East Spring 0.8 5.83 1.13 8.26

Lonetree Spring 0.98 6 1 6.15

Burro Spring 0.93 2.53 7.17 19.5

Pipe Creek 0.713 2.47 12 41.5

Pumphouse Spring 1.7 1.8 2.59 2.74

Pumphouse Wash Gage 2 1.8 178.7 161

Horn Creek 2.67 15.6 8.41 49.3

Salt Creek Spring 2.23 30 3.91 52.6

Monument Creek #1 0.52 7.1 55.8 761

Monument Spring 4 7.2 586 1060

Hawaii Spring 0.77 1.93 548 1380

Hermit Spring 1.6 2.05 1140 1470

Boucher East Spring 0.47 1.8 5.47 20.8

Sum Output 2750 grams 5070 grams

6.06 pounds 11.2 pounds

% of Colorado River Load 0.013% 0.0086%

Table VIII. Havasu Creek and Little Colorado River Averaged Concentration and Annual Release Data from USGS OFR-96-614

Sampling Site Concentration Concentration Arsenic release Uranium release

ppb arsenic ppb uranium grams/year grams/year

Havasu Creek 11.4 3.75 714,000 234,000

Little Colorado River 6.85 8.87 1,330,000 1,740,000

Sum Output 2,044,000 grams 1,974,000 grams

4,500 pounds 4,350 pounds

% of Colorado River Load 10.96% 3.35%


A type-example of the contribution of uranium to Redwall-Muav aquifer ground water by a uranium-mineralized collapse breccia pipe The Hermit-Supai stratigraphic interval containing uranium and other metals in uranium-mineralized collapse breccia pipes is above the Redwall-Muav aquifer. See Figure 2 above. However, ground water migrating downward from the surface into the aquifer below can26 pass through a mineralized breccia pipe and gradually leach the metal-bearing minerals contained in the pipe. The question is: What is the likely magnitude of such natural uranium leakage into the Redwall-Muav aquifer? USGS sampling (Monroe et al., 2004) of a creek flowing out of the drainage cell27 containing the mineralized breccia pipe developed by the Orphan Mine provides evidence of the magnitude of remobilization of trace metals in this pipe by descending ground water. The Orphan Mine is located immediately east of the Powell Memorial on the South Rim of the Grand Canyon and west of Grand Canyon Village. A vertical cross-section of this breccia pipe and its mine development is shown in Figure 16. By the time the mine was closed in 1969, the Orphan Mine pipe had yielded a total of 4.26 million pounds of U3O8, 6.68 million pounds of copper, and 107 thousand ounces of silver (Billingsley et al., 1997, pp.61-64). Once it was recognized in the early 1950s that the Orphan pipe contained uranium, the mine’s owners installed an aerial tramway and bucket system for removing 800 pounds of ore at a time. In order to increase ore production rates 900% over earlier tramway ore production, a vertical shaft and hoist system was completed in 1959.28 The ongoing29 effect of the presence of this mineralized breccia pipe has on the water quality of one South Rim creek can be gauged by reference to published geological and hydrological observations of the Grand Canyon South Rim area. According to the Final

Environmental Impact Statement for Tusayan Growth (USDA 1999, p. 154),

“Sources of recharge for the small springs and seeps are believed to be small, local drainage basins at the canyon rim; these small springs and seeps are considered to be poorly connected or not connected hydraulically to the large-scale ground water movement in the regional Redwall-Muav aquifer.”

26 Not all breccia pipes are exposed to the weathering surface and so are less likely to be subjected to amplified ground water recharge caused by such factors as direct exposure to precipitation, the precipitation-funneling effects of in-dipping sedimentary rocks, and/or normal drainage-related concentration of run-off. 27 A “drainage cell” is the portion of the surface area of the earth that focuses and provides surface water run-off (and more vertical ground water recharge) to a specific downstream part of the drainage system. 28 The Grand Canyon National Park began disassembling this 50 year-old landmark in early 2009. 29 “Ongoing”: The waters draining the section of rock containing the Orphan Mine breccia pipe have a minimum residence time in the rock of 800 years, according to USGS 14C and tritium analyses of Horn Creek water samples (Monroe et al., 2004). This age suggests modern-day recharge waters passing through the Orphan Mine breccia pipe have yet to come to surface in the Horn Creek drainage, and will not do so for about another 1000 to 1200 years.


Figure 16. Taken from Figure 24 of GJBX-143(81)30

30 Available online as www.admmr.state.az.us/DigitalLibrary/AEC-DOE/GJBX143-81UraniumProductionArizonaPart1.pdf


Further (p. 155), “The average recharge rate of 10 gpm [gallons per minute] per square mile indicates that ground water drainage areas for the seeps and small springs along the South Rim would range from a fraction of a square mile to a few square miles.”

Figure 17 shows the drainage and recharge area of approximately 0.39 square miles feeding the USGS Horn Creek sample site in blue outline. The sub-basin containing the Orphan Mine breccia pipe is outlined in red and is about 0.02 square miles in area. The contour line plot overlay of ground water residence time indicates that it takes approximately 1200 years for water descending through the Orphan Mine area to eventually reach the surface in Horn Creek.31 Decrease of average water residence time from the Orphan Mine to the Horn Creek sample site apparently reflects the increase of the influence of younger, descending ground water on Horn Creek waters as the thickness of rocks overlying the Redwall-Muav aquifer decreases.32 Likely (expected) case breccia pipe uranium leachate concentrations Assuming the existence of no other mineralized collapse breccia pipe within the blue outlined drainage and recharge area shown on Figure 17, using the USGS hydrogeochemical uranium and flow rate data for Horn Creek, and knowing that uranium is stable in solution in Horn Creek ground water,33 it becomes possible to:

1. Estimate the annual amount of uranium remobilized from the Orphan Mine breccia pipe (‘annually’ about 1000-1200 years ago, that is); and,

2. Estimate the average concentration of uranium in descending ground water after it

has completed passing through a mineralized breccia pipe. Monroe et al., 2004 (Table 8, pages 37 and 52) provides the following measurements for Horn Creek:

Table IX. Horn Creek Repeated Water Analyses (USGS)

Sampling Date ppb Uranium Discharge (L/min)

05-22-00 8.6 3.4

12-06-00 9.3 5.1

04-07-01 29 9.5

31 Among other things, this means that the uranium and radioactivity observed in the Horn Creek drainage below the South Rim is most likely the result of leaching of the Orphan Mine ore zone that took place some 1200 years ago, and most likely does not reflect any potential adverse effect from the mining of this particular breccia pipe. 32 The thinner the section of rock overlying an aquifer, the quicker that descending modern-day precipitation can arrive at the water table and mix with older waters moving in a more horizontal direction. 33 234U/238U activity ratio data provided by Fitzgerald (1996, p. 43) show the dissolved uranium of Horn Creek drainage ground water is stably kept in solution (is “conservative”).


Figure 17. Orphan Mine area ground water recharge area with USGS (2005) average residence time of waters.


Discarding the 04-07-01 sample analysis, for reasons discussed in the following section, yields an average flow rate of 4.25 L/min with an average dissolved uranium concentration of 9.0 ppb. This flow rate indicates an annual average aquifer recharge rate of: (4.25 L/min x 60 min/hour x 24 hrs/day x 365 days/year x 1 m3/1000 L)/1,019,475 m2

= 2.19 x 10-3 m/year = .086 inch/year34, for the Horn Creek/Orphan Mine water table recharge area. Discounting ephemeral pulses of run-off like those measured on 04-07-01, annual release of uranium to the Colorado River drainage by the Orphan Mine breccia pipe can be estimated by the following equation: = (9.0 ppb U x 4.25 L/min x 60 min/hour x 24 hrs/day x 365 days/year x 1000 g H2O/L) 1 x 109

= 20 grams U/year = 0.71 ounces U/year Assuming that all uranium in the ground water draining out of the Horn Creek drainage cell originates in the 50,800 m2 Orphan Mine sub-basin, and that the recharge rate for the Orphan Mine sub-basin is equal to the 2.19 x 10-3 m/year (~0.1 inch/year) recharge rate calculated for the whole Horn Creek drainage, the volume of water passing through the Orphan Mine breccia pipe each year is about: = 2.19 x 10-3 m/year x 50,800 m2 = 111 m3; or, 111 m3 x 1000L/m3 = 111,000 L The total recharge volume for the Horn Creek drainage is: = 2.19 x 10-3 m/year x 1,019,475 m2 = 2,230 m3; or 2,230 m3 x 1000L/m3 = 2,230,000 L Estimating uranium concentration of waters passing directly out of the Orphan Mine35 is possible by making a volumetric calculation: 2,230,000 L x 9.0 ppb U = Total Annual Recharge Volume Horn Creek basin x Water average U concentration = Orphan Mine Sub-Basin Annual Recharge Volume x Average U concentration of water draining Orphan Mine pipe = 111,000 L x X; where X = average U concentration of water draining Orphan Mine pipe: 2,230,000 L/year x 9.0 ppb U = 111,000 L/year x X; X = 180 ppb36 U

34 Which is within the 0.1 to 0.3 inch/year recharge rate range calculated by Metzger (1961) for South Rim springs and seeps. 35 Probably about 1000-1200 years ago, that is. 36 This more concentrated dissolved uranium level is eventually diluted by mixing with ground water recharge waters not containing pipe-leached uranium to reach the average 9 ppb uranium value of Horn Creek water.


Worst case uranium leachate concentrations The estimated annual volume of water passing through the Orphan Mine and knowledge of maximum likely uranium solubility in water as a uranyl sulfate complex also permit an estimate of the maximum annual natural contamination rate of the Redwall-Muav aquifer from an Orphan-like uranium-mineralized breccia pipe under the currently evidenced rates of Redwall-Muav aquifer recharge in the Horn Creek drainage. Judging from the extremely strong correlation between uranium concentration and sulfate concentration in waters collected from the South Rim, uranium exists in solution in these waters as very stable and non-reactive uranyl-sulfate complexes.37 See Figure 18. Oxidation of pyrite intimately associated with uranium ore in collapse breccia pipes would provide an immediate and concentrated SO4

2- ligand source for the formation of solution-stable uranyl-sulfate complexes. Oxidation of pyrite in the presence of water forms concentrated sulfuric acid, H2SO4. Field observations (Hockley, Day, and Bowell, 2000)38 show that the maximum dissolved uranium level of mine waters that were brought into solution in the presence of concentrated sulfuric acid, and which were then neutralized to slightly acidic to neutral pH in the presence of carbonate material, is about 25 ppm U.39 In neutral to alkaline oxidizing waters like those sampled in the USGS studies sampling Redwall-Muav ground water, it would generally be expected that uranium in solution exists as carbonate, rather than sulfate, complexes (Hockley, Day, and Bowell, 2000). Figure 19 indicates that this is not the case in the Coconino Plateau region, however. As can be seen in the Figure, there is a weak, but significant inverse relationship between water dissolved carbonate concentrations and the concentrations of uranium in the water samples. This weak, but significant inverse relationship shown in the graph is believed to reflect the dominance of uranyl sulfate complexing in waters draining sites containing uranium mineralization and the dominance of uranyl carbonate complexing in waters originating from unmineralized areas.

37 Uranium becomes extremely non-reactive, and therefore conservative, in solution when it is surrounded (chelated) by other anions or ligands like carbonate (CO3

2-), sulfate (SO42-), and certain organic acids. The

increased diameter of the uranium-ligand complex spreads out or neutralizes the positive charge of the central uranium atom, thus making it less reactive towards its solid and liquid external environment. Lesser reactivity insures that the uranium comes into and remains in solution. The “R-squared” value of 0.772 on Figure 18 indicates that 77% of the variation in the dissolved uranium in the South Rim creeks and springs can be explained by changes in the concentration of SO4

2-, sulfate, in each creek or spring. This very

strongly suggests that, on the average, only 23% of the water concentration of uranium is caused by

variations in the uranium concentrations of the rock containing the ground waters. 38 http://www.imwa.info/docs/imwa_2000/IMWA2000_35.pdf. 39 Note that the 1986 Canyon Mine EIS (p. 4.39) used a value of only 1 ppm dissolved uranium in its analysis of the same matter.


Figure 18. Evidence of uranium-sulfate complexing in the Redwall-Muav aquifer waters emerging from

the springs and creeks on the south rim of the Grand Canyon.40

40 In order to increase the accuracy of the “line-of-best-fit” shown above, the data points for the Salt Creek, Horn Creek, and Monument Creek and Monument Spring were left out of the statistical line-of-best-fit estimation process. This is because each sample evidenced a uranium value well above the initially estimated line-of-best-fit, a fact that indicates that, among other things, the uranium levels of the rocks that these particular ground waters pass through are having a larger than normal (i.e., greater than 23%) effect on the ground water concentrations of uranium. This makes sense, as each named excluded water sample source is proximal to the mineralized breccia pipe cluster that includes the Orphan Mine.


Again, the estimated annual volume of water passing through the Orphan Mine and knowledge of maximum uranium solubility in water as a uranyl sulfate complex also permit an estimate of the theoretical maximum annual natural contamination rate of the Redwall-Muav aquifer from an Orphan-like uranium-mineralized breccia pipe under the currently evidenced rates of Redwall-Muav aquifer recharge in the Horn Creek drainage: 111,000 L/year containing 25 mg/L uranium mobilizes 111,000 L/year x 25 mg/L uranium = 2,775,000 mg uranium/year = 2.78 kg uranium per year, or 6.1 pounds uranium per year. This calculation envisions an annual water table recharge rate of about 0.1 inch per year. Assuming Metzger’s (1961) maximum annual ground water recharge rate of 0.3 inches/year is more realistic, yields an absolute maximum natural release of 8.3 kg uranium per year to the Muav-Redwall aquifer, or about 18.4 pounds of uranium per year by the Orphan Mine breccia pipe. Summary If the Orphan Mine breccia pipe case is taken as representative of other mineralized collapse breccia pipes in the Grand Canyon region, these estimates of natural maximum annual breccia pipe contribution of dissolved uranium to the Redwall-Muav aquifer should be representative for both the case of a mined breccia pipe, and the case of an unmined breccia pipe. As already explained, two separate factors limit the amount of breccia pipe uranium that can be mobilized by ground water:

1) The annual amount of recharge waters passing down through the rock section containing the uranium-mineralized breccia pipe, and 2) The maximum likely amount of uranium that can be dissolved in such ground

water. Whether or not a uranium breccia pipe is disturbed by mining does not affect, at least

initially,41

the maximum amount of uranium that can be mobilized by descending ground

water down to the underlying water table. The limiting factors of uranium solubility in the presence of sulfides (and carbonate rocks), and the amount of surface precipitation do, however, affect and restrict the amount of pipe uranium leached down into the Redwall-Muav aquifer waters from uranium-mineralized breccia pipes. Figure 20 summarizes the breccia pipe uranium contamination models described above.

41 “Initially”: Once the uranium ore is more or less completely removed by mining, the amount of uranium that can be leached into the water table each year will decrease markedly because the economic, higher concentration parts of the uranium mineralization have been removed from the rock and are no longer subject to leaching by descending ground water.


Figure 19. Weak evidence of uranium-carbonate complexing in the Redwall-Muav aquifer waters emerging from the springs and creeks on the south rim of the Grand Canyon.

USGS (2005) data. In order to increase the accuracy of the “line-of-best-fit” shown above, the data points for the Salt and Horn Creeks were left out of the statistical line of best fit estimation process. This is because each sample evidenced a uranium value well above the initially estimated line-of-best-fit, a fact that indicates that, among other things, the uranium levels of the rocks that these particular ground waters pass through are having a larger than normal effect on the ground water concentrations of uranium. This makes sense, as each named excluded water sample source is relatively proximal to the mineralized breccia pipe cluster that includes the Orphan Mine. The weak, but significant inverse relationship shown here is believed to reflect the dominance of uranyl sulfate complexing in waters draining uranium mineralization, and the dominance of uranyl carbonate complexing in unmineralized areas. The low-carbonate Monument Springs and Monument Creek sample are most proximal to the Horn and Salt Creek samples excluded here.


Possible Causes of Seasonal Increases of Uranium Concentration in Horn Creek Waters

Table IX of USGS data shows that at high flow/high run-off rate of 04-07-01, the uranium concentration of Horn Creek increases, rather than decreases. A decrease in uranium concentration due to the temporary influence of uranium-poor rain or melt water would have been expected under such conditions. The sampling work of Fitzgerald (1996) for 03-19-95 shows the same effect at entirely different sampling sites in the same

general drainage.42 See Table X. One possible explanation of this run-off related increase in uranium concentration, observed in both the USGS report and the Fitzgerald graduate study report, is that it is related to leaching of Orphan Mine ore material lost at the Orphan Mine top of the Horn Creek drainage during the period of time in the 1950s that the aerial tramway was being used to move ore up out of the mine. The bucket used on this tramway reportedly had short sides, making it possible that some Orphan Mine uranium ore was inadvertently lost, from time to time, over the Coconino cliff face at the bottom of the tramway, down into the Horn Creek drainage channel below.

Table X. Fitzgerald (1996) Horn Creek Seep Analyses

Note the extremely low discharge rates of the Fitzgerald sample sites and compare those to the much higher flow rates of the USGS samples in Table IX above.

Sampling Date ppb Uranium Discharge (L/min)

04-30-94 24.7 --

03-19-95 92.7 1.5

06-05-95 27.6 0.25

During the short, seasonal pulses of high surface run-off, it is possible that this surface run-off down the Orphan-to-Horn Creek erosional chute leaches enough uranium to temporarily ‘kick up’ the uranium concentration of water flowing in the lower reaches of the Horn Creek drainage. Figure 21 illustrates the juxtaposition of the former course of the aerial tramway and the Orphan-to-Horn Creek erosional chute. Sampling and analysis of the sediments deposited and distributed all along the chute -- particularly sub-sampling and analyses of high density concentrates generated from these sediment samples -- would be required to determine if this hypothesis correctly explains the origin of the seasonal increases in the uranium content of Horn Creek waters. A reading of Winde et al (2004)43 suggests a second possible explanation: Namely, that highly soluble uranium-rich uranyl sulfate crusts can accumulate by dry season evaporative concentration of waters carrying uranium in sulfate complexes -- waters like

42 Fitzgerald reports that all of his water samples were collected from seeps emerging from sediment in the Horn Creek drainage. At high flow, his sampling was conducted about 0.75 mile up the drainage from the Tonto Trail. At low flow, his Horn Creek drainage water samples were collected 200 feet (upstream? downstream?) from the trail. 43 http://www.wrc.org.za/archives/watersa%20archive/2004/Apr-04/10a.pdf.


those found in the South Rim springs and creeks. In the referenced South African example, evaporative concentration of soil and sediment capillary zone waters that are moderately high in uranium results in the surface deposition of a very highly-enriched crust of uranium sulfate. These surface mineral crusts can then be rapidly re-dissolved during wet season run-off to yield a much higher than normal uranium concentration pulse of spring or creek waters, waters like those observed to flow out of the Horn Creek drainage during periods of high surface water run-off. Sampling and analysis of the sediments deposited and distributed all along the chute -- particularly sampling of surface mineral crusts -- would be required to determine if this hypothesis correctly explains the origin of the seasonal increases in the uranium content of Horn Creek waters. Under this hypothesis, no surface contamination from the Orphan Mine would be necessary to explain the increase in Horn Creek water concentrations of uranium during periods of high water surface run-off. The uranium sulfate evaporatic mineralization process could be acting just upon normal Redwall-Muav ground water naturally leached from the rocks proximal to the Orphan Mine. Keep in mind that a combination of the mechanisms described in each of the two hypotheses proposed here could just as well be behind the episodic increases in uranium concentration levels of the Horn Creek waters.


Figure 20. Summary model of Orphan Mine contribution of uranium to the Redwall-Muav aquifer.


Figure 21. Overflow of Orphan Mine aerial tramway bucket could have spilled uranium ore into the west side of the Horn Creek drainage cell.


Air Quality, Radiation, and Noise Levels

Air Quality

Grand Canyon National Park has been assigned Class I airshed status. Under this designation, the area is supposed to meet the highest standards for airborne pollutants of the Clean Air Act (USFS 1999). Although air quality is generally good in the area, it is affected from time to time by seasonal temperature inversions, and weather changes that carry pollutants into the area from the Navajo Generating Station at Page, Phoenix, Las Vegas, and Los Angeles. Local emissions from cars, buses, trains, and wood-burning stoves accumulate under wintertime cold air inversions. In the summertime, average visibility at Grand Canyon National Park drops from an average of about 160 miles to 100 miles when winds from the south and west bring in air pollutants from Phoenix, Las Vegas, and Los Angeles. Controlled burns conducted by the NPS and USFS in the warmer months, and dry season road dust, also reduce visibility in the Grand Canyon area. As was similarly explained in the Canyon EIS (1986), in the event of Proposed Plan approval, only particulates would be emitted to the air by uranium exploration or possible later mining operations. Particulate data have been collected by the Park Service at Hance Camp in the Grand Canyon National Park as part of the IMPROVE Aerosol Network for a number of years. The three most recent years of sampling on record at http://vista.cira.colostate.edu/views/Web/Data/DataWizard.aspx show the following total suspended particulate (10 µ-m and smaller aerosol particles) concentrations:

Table XI. Total Suspended Particulates, 10 µ-m and Smaller, Collected at Hance Camp by the National Park Service

Year 2004 2005 2006

Annual Average 5.13 µ-g/m3 5.16 µ-g/m3 5.59 µ-g/m3

Standard Deviation

3.75 µ-g/m3 3.89 µ-g/m3 3.66 µ-g/m3

Annual Range 0.582-18.7 µ-g/m3 0.205-18.3 µ-g/m3 0.831-22.7 µ-g/m3

Number of Samples

121 120 119

Because the Proposed Plan of Operations would take place within 20 miles of the Hance Camp air quality measurement station, and because of this proximity and the consequent similarity in climatology and exposure to point and major sources of emissions, the Hance Camp data are expected to be representative of the baseline particulate concentrations for the Proposed Plan of Operations area. It is anticipated that the concentration of total suspended particulates in the air will usually be about 5.3 µ-g/m3, and range infrequently from as low as 0.2 up to 23 µ-g/m3 (this last especially during fire season or during controlled burns).


Background Radiation and Radon Gas

The nearest survey area for background radiation to the Proposed Plan of Operations is the Canyon Mine Site, which has been sampled (1986, p. 3.27-3.28) in order to establish baseline levels of radiation in air and water before the onset of mining operations there. Each of the operations sites covered by the Proposed Plan of Operations is located within the same rock type and within 10 miles of the Canyon Mine Site. For these reasons, it is believed that measurements obtained at Canyon Mine are representative of the maximum radiation conditions that exist at each of the Kaibab JV Project areas. It is established that economic concentrations of uranium ore exist in the subsurface at the Canyon Mine, but the existence of this characteristic is still uncertain at each of the Proposed Plan of Operations project areas. All other things being equal, higher background radiation levels would be expected at mineralized locations like the Canyon Mine than at unmineralized sites. At the Canyon Mine, whole body background radiation ranges between 90 and 130 m-rem/year. In contrast to this radiation exposure at the Canyon Mine site, the typical whole body background radiation dose for a person living at elevations between 7000 to 7500 feet on the Colorado Plateau, who watches television, uses a computer, and gets one medical or dental X-ray a year, is about 450 m-rem/year.44 Background radon concentrations in proximity to the Canyon Mine were found to range from 0.2 to 0.8 pCi/L, concentrations that correspond to a lung dose of radiation of 125 to 500 m-rem/year. The typical outdoor radon-imposed lung radiation exposure in the western US is about 125 m-rem/year, while indoor air radon-imposed lung doses can vary from 125 up to 3,125 m-rem/year (i.e., in a modern energy-efficient home with consequently limited ventilation).

Noise

Currently, the major sources of noise in the Proposed Plan of Operations area caused by human activity are: Vehicle traffic along Highway 64, rare to common (depending on hunting seasons) ATV and 4WD truck sounds, and occasional overhead jet and helicopter traffic. Major common sources of non-human noise in the area include wind, foliage-rustling, and animal and insect noises. According to the USFS (1986), the day-night average sound level (Ldn) for unpopulated areas well away from paved roads and Grand Canyon area tourist industry air travel corridors (like those common in the northern portions of the Tusayan Ranger District) can be expected to vary between 30 to 45 decibels (dBA). Each project area in the Proposed Plan of Operations is located within a shallow basin or drainage. These drainages or basins themselves are surrounded by tree-covered, low ridges that attenuate sound. With the exception of the Sze Prospect, which is adjacent to Highway 64 but largely shielded from traffic view by tree cover, each exploration drilling project is 0.75 miles or more from a paved road. The only human noise receptors in the vicinity of each of the project areas are rare recreational visitors, USFS employees, and occasional mineral exploration workers.

44 EPA annual radiation dose calculator result obtained at http://www.epa.gov/rpdweb00/understand/calculate.html


Biological Resources

Introduction

DIR Exploration, Inc., retained W. Leibfried Environmental Services to conduct field data collection and habitat evaluation, data evaluation and species effects determination, and compose wildlife/ESA (BAE), vegetation and range and watershed/soils reports in the Red Butte area of the Tusayan Ranger District, Kaibab National Forest, acceptable to the Kaibab National Forest. The biological resource inventory covers three 40-acre parcels (Bozo, Grandpa, and Two Squares), three 60-acre parcels (Garfield, Maybe, and Sze), and approximately 1.6 miles of access roads for the Grandpa, Maybe, and Two-Squares prospects. The work described was conducted by biologist William Liebfried, field botanist Mimi Murov, and applied geographer/GIS specialist Glenn Dunno.

Field Botany

This section analyzes the potential effects of the DIR Exploration, Inc./Kaibab Joint Venture Uranium Exploration Drilling project on plant species. These effects are evaluated for plant species listed under the Endangered Species Act of 1973 (ESA), and those classified as Sensitive by the Southwest Region (R3) of the U.S. Forest Service (USFS). The six proposed exploratory drill projects are located within Ecosystem Management Areas (EMA) 8 and 10. Vegetation within EMA 8 is dominated by pinyon pine (Pinus

edulis), and juniper (Juniperus sp.) and EMA 10 is dominated by ponderosa pine (Pinus

ponderosa). Other common vegetation includes, rubber rabbitbrush, (Chrysothamnus

nauseosus), blue grama grass, (Bouteloua gracilis), broom snakeweed, (Gutierrezia

sarothrae), and big sagebrush (Artemisia tridentata). Elevations at the drill sites range from 6200-6800 feet above sea level The vegetation currently on the sites is a mosaic of Great Basin Conifer Woodland, Great Basin Desertscrub, and Petran Montane Conifer Forest (Brown 1994). The Bozo site is dominated by woodland but also includes elements of desert scrub and ponderosa pine forest. The upland areas of Two Squares and Grandpa are also dominated by woodland. Lowland areas of Two Squares and Grandpa are dominated by desert scrub. The remaining sites are dominated by ponderosa pine and each includes elements of woodland and, to a lesser extent, desert scrub. Woodland areas are dominated by mature pinyon– juniper with some ponderosa pine. Canopy cover is generally one story and open with little to no intertwining canopy. Total general cover is estimated at no more than 20% in the densest clumps. Understory is open and includes cliffrose (Cowania mexicana), broom snakeweed, rubber rabbitbrush and Fremont barberry (Berberis fremontii) A variety of perennial forbs and grasses occur, including winged buckwheat (Eriogonum alatum), sulfur flower (Eriogonum

umbellatum), skyrocket (Ipomopsis aggregata), blue grama grass, muhly grass (Muhlenbergia sp.) squirrel tail (Elymus elymoides) and Hymenoxys richardsonii There are scattered pinyon and juniper snags and down logs.


Big sagebrush and rubber rabbitbrush are the most common plants in the Great Basin Desertscrub sites. Other common shrubs include broom snakeweed, four-winged saltbush (Atriplex canescens),and fringed sagebrush (Artemisia frigida). Common herbaceous species include blue grama grass and Hymenoxys richardsonii. Forested areas are dominated by ponderosa pine with pinyon, juniper and/or oak (Quercus gambelii) mid story. Ponderosa stands range from doghair thickets to mid-seral blackjack stands to mature park like stands of yellow pine. There are scattered snags or down logs. Woodland species within the forested areas range from saplings to mature individuals. Most of the oaks occur in small discrete groves with few individuals having root base diameters greater than or equal to five inches. These few occur in the Garfield site. Canopy cover in general is estimated at less than 10-20%, with only scattered areas of interlocking canopy. Understory is mostly composed of shrubs. Common species include rubber rabbitbrush, broom snakeweed, cliffrose, and big sagebrush. There are also a variety of perennial forbs and grasses. Common species include sulfur flower, skyrocket and Hymenoxys richardsonii, Blue grama grass is the most common grass. Other grasses include squirrel tail, muhly grass, needle grass (Achnatherum speciosa) and side oats grama (Bouteloua curtipendula). The Arizona Game and Fish Department (AGFD) maintains a statewide database, known as the Heritage Data Management System (HDMS), which tracks records for federally listed species and other species of special concern. The HDMS database was searched for occurrence records of special-status plant species near each of the proposed drill sites. In addition, the U.S. Fish and Wildlife Service (USFWS) online database (USFWS 2008) was accessed to obtain information on federally listed species that may potentially occur in Coconino County. These lists, in addition to the USFS KNF Sensitive Species list for the Tusayan and Williams RDs, were used to compile the list of species considered. Sensitive species are defined as “those plant and animal species identified by a Regional Forester for which population viability is a concern, as evidenced by: a) significant current or predicted downward trends in population numbers or density; or b) significant current or predicted downward trends in habitat capability that would reduce a species’ existing distribution [Forest Service Manual 2670.5(19)].” Only those plant species that have USFWS or USFS status were included in this evaluation. The potential for occurrence of special-status plant species was evaluated based on

1) existing information;

2) qualitative comparisons between the known habitat requirements of each species and vegetation communities, aquatic resources, and other conditions found in the project vicinity, based on the experience and knowledge of the field investigators; and

3) Field surveys conducted on November 15 and 23, 2008. Nine federally listed species and sixteen species identified on the KNF Sensitive Species lists are addressed in this report (Tables XII and XIII). Species that had HDMS occurrence records within 5 miles of any proposed drill site are discussed in further detail.


Field investigations were conducted to survey for habitat and occurrence of sensitive plant species on November 15 and 23, 2008. No federally listed, nor KNF sensitive,

plants were observed during field surveys. Habitat was not present for the majority of sensitive plants during the surveys and those species were omitted from further analysis. The five species that may have habitat in the area are Mt. Dellenbaugh sandwort, Arizona leatherflower, Flagstaff beardtongue, Flagstaff pennyroyal, and Tusayan rabbitbrush. These five species were further evaluated for potential impacts from the proposed drilling (Table XIV). The status, habitat, and distribution of the relevant plant species are discussed below.

Table XII. U.S. Fish and Wildlife Service List of Plants in Coconino County, AZ

Common Name (Scientific Name) Status Elevation, Habitat, and Range

Welsh milkweed (Asclepias

welshii) Threatened

4700-6200'. Found 5 miles N of N Kaibab RD. Designated critical habitat is in Utah. Open stabilized desert scrub dunes and lee side of active dunes. Sagebrush, juniper, pine, and oak.

Sentry milk vetch (Astragalus

cremnophylax var.

cremnophylax) Endangered

7050-7960'. Found at Grand Canyon National Park on the canyon rims about 5 miles from the Kaibab NF. Kaibab limestone (white to gray-white member with abundant large nodules and fossils). Crevices or shallow soil on exposed ledges or canyon rims. Full sun. Pinyon, juniper, cliffrose.

Navajo sedge (Carex

specuicola) Threatened

3400-7000'. Found from Navajo Creek drainage E to Mexican Water. Designated critical habitat is on the Navajo Nation near Inscription House Ruins. Seeps on vertical cliffs of pink-red Navajo sandstone. Silty soils. Hanging gardens.

Arizona bugbane (Cimicifuga

arizonica) Conservation Agreement

4700-8800'. Found on Bill Williams Mountain and Oak Creek Canyon. Canyon bottoms and lower slopes, drainages, seeps and springs. Moist, loamy soil, high in humus content. Deep shade, high humidity, north slopes. Between coniferous and riparian habitats with Douglas-fir, white fir, Rocky Mountain maple, and aspen.

Brady pincushion cactus (Pediocactus

bradyi) Endangered

3340-5200'. Found near Marble Canyon for about 25 miles downstream from Lee’s Ferry; about 15 miles north of the N Kaibab RD. Canyon rims, benches, terraces. Kaibab limestone and Moenkopi shale and sandstone. Shadscale saltbush, broom snakeweed, green Mormon tea, and desert trumpet buckwheat.

Kaibab pincushion cactus (Pediocactus

paradinei) Conservation Agreement

5000-7200'. Found only on the E Kaibab monocline on the N Kaibab RD and in the adjoining House Rock and Coyote Valleys. Open and level sites (0-15% slopes) on alluvial fans, bottoms, and ridges. Kaibab limestone, gravelly soils high in calcium carbonate and low in clay. South slopes, grassy openings. Grassland, sagebrush, desert scrub, pinyon-juniper woodland, and lower ponderosa pine forest. Big sagebrush and blue grama.

Fickeisen pincushion cactus (Pediocactus

peeblesianus var.

fickeiseniae) Candidate

4000-6000'. Found on N Kaibab RD, but mostly found on BLM (House Rock Valley and Mohave County) and Navajo Nation lands (Little Colorado River Gorge). Canyon rims, ridges, benches, hills, foot of cliffs on slight to moderate slopes. Kaibab limestone, Moenkopi Formation, and Shinarump Conglomerate. Gravelly loam soils.


Siler pincushion cactus (Pediocactus

sileri) Threatened

2800-5800'. Found in Arizona from the Hurricane Cliffs to Fredonia. Potential habitat may occur in Kanab Canyon on the N Kaibab RD. Red or gray gypsiferous badlands of the Moenkopi formation. Gypsiferous, seleniferous, calcareous soils high in soluble salts. Clayey or sandy soils. Desert scrub transitional areas of Navajo, sagebrush, and Mohave Deserts.

San Francisco Peaks groundsel (Senecio

franciscanus) Threatened

11000-12300'. Designated critical habitat is San Francisco Peaks. Alpine talus cracks and crevices of fine to medium grained volcanic soils. Alpine tundra.

Table XIII. USDA Forest Service Southwestern Region List of Sensitive Plants found on the Kaibab National Forest

Common Name (Scientific Name)

Elevation, Habitat, and Range

Mt. Dellenbaugh sandwort (Arenaria

aberrans) 5500-9000’. Found N of Williams, at the South Rim of Grand Canyon National Park, and in De Motte Park on the N Kaibab RD. Basalt soil or sandy soils. Meadows and meadow edges within oak and pine forests or in pinyon-juniper woodlands.

gumbo milkvetch (Astragalus ampullarius)

3200-5400'. Found on the N Kaibab RD. 5-20% slopes. Chinle and Moenkopi formations. Clayey, silty clay, very sandy, saline, and seleniferous soils. Pinyon-juniper woodland or mixed desert shrub with Atriplex and Eriogonum species.

Marble Canyon milkvetch (Astragalus

cremnophylax var.

hevronii)

5200-5400'. Known only from E rim of Marble Canyon on the Navajo Nation, about 1 miles from the N Kaibab RD. Suitable habitat occurs nearby on the N Kaibab RD. Rims of canyons on 0-5% slopes. Kaibab limestone. Small, shallow pockets and small cracks in the bedrock or in very shallow soils. Full sun. Great Basin desert scrub habitat.

cliff milkvetch (Astragalus

cremnophylax var.

myriorrhaphis)

6200-7900'. Endemic to the Buckskin Mountains on the N Kaibab RD and on BLM land. Cliff ledges, cliff faces, rock benches, and pillars on 0-5% slopes. Kaibab limestone (white or gray-white member with lots of nodules and fossils). Small, shallow pockets and small cracks in the bedrock or on very shallow soils. Full sun or very little shade. Great Basin Conifer Woodland with pinyon, juniper, sagebrush, and cliffrose. Rusby milkvetch

(Astragalus rusbyi) 5400-9000’. Found on the lower slopes of the San Francisco Peaks, in Oak Creek Canyon, N of Williams, Kendrick Peak, Garland Prairie, and Camp Navajo. Dry or temporarily moist basaltic soils. Openings or meadows in ponderosa pine forest or at the edge of thickets and aspen groves. Also found in mixed conifer and pine-oak forests in openings.

Kaibab paintbrush (Castilleja kaibabensis)

8200-9000’. Found in De Motte Park, Pleasant Valley, Upper Little Park, and other small nearby parks on the Kaibab Plateau on the N Kaibab RD. Kaibab limestone. Low rounded ridge tops and knolls. Shallow coarse silty, clayey, sandy loam, or rocky and gravelly soils. Dry exposed sites without much competition from grasses and forbs in open subalpine meadows and montane grasslands.

Tusayan rabbitbrush (Chrysothamnus

5700-6900’. Found on north end of the Coconino NF and on portions of the South


Arizona leatherflower (Clematis hirsutissima

var. hirsutissima)

6900-8500’. Found along the Rio de Flag, Lower Lake Mary, and upper Volunteer Canyon on the Coconino NF and in the Tusayan area of the Kaibab NF. Rocky hillsides with 12-40% slopes. Kaibab limestone. Rock outcrops and shallow soils. Moist mountain meadows, prairies, and open woods and thickets in ponderosa pine and mixed conifer forests.

rock fleabane (Erigeron

saxatilis) 4400-8400’. Dacite or Coconino sandstone. Sheer canyon walls. Moist north-facing slopes. Riparian deciduous forest and other habitat types.

Morton wild buckwheat (Eriogonum

mortonianum)

4650-4670’. Found SW of Fredonia along HW 389 on Kaibab-Paiute Reservation and AZ SLD lands. Potential habitat may exist in Kanab Canyon on the N Kaibab RD. Small drainages. Moenkopi formation sandstone and shale. Very shallow red gypsiferous sandy clay. Full sun. Great Basin desert shrub. It occurs with the equally rare Atwood wild buckwheat.

Atwood wild buckwheat (Eriogonum thompsonae

var. atwoodii)

4400-4700’. Found SW of Fredonia along HW 389 on Kaibab-Paiute Reservation and AZ SLD lands. Potential habitat may exist in Kanab Canyon on the N Kaibab RD. Small drainages. Moenkopi formation sandstone and shale. Shallow red gypsiferous clay or loam. Full sun. Great Basin desert shrub. It occurs with the equally rare Morton wild buckwheat and hybridizes with it.

Flagstaff pennyroyal (Hedeoma diffusum)

4500-7100’. Found near Flagstaff in Walnut Canyon drainages, on the rims of Oak Creek and Sycamore Canyons, Bill Williams Mountain, and north of Tule Canyon. Rock pavement, cliffs and breaks on 0-10% slopes. Kaibab formation dolomitic limestone or sandstone. Outcrops, boulders, rock crevices and pockets, or shallow soils. Ponderosa pine forests.

Kaibab bladderpod (Lesquerella kaibabensis)

8300-8900’. Found mostly along HWY 67 on the Kaibab Plateau on the N Kaibab RD. Knolls. Kaibab or Toroweap formation limestone. Rock outcrop, clayey, or sandy loam soils with lots of surface rock. Open windswept and dry subalpine meadows. Full sun.

Mt. Trumbull beardtongue (Penstemon

distans)

3900-5200’. Found on BLM lands in Whitmore, Parashant, and Andrus Canyons and near Mt. Trumbull on the SE edge of the Shivwits Plateau. Potential habitat is in the vicinity of Kanab Canyon on the N Kaibab RD. Mesa tops, steep slopes, and canyons. Kaibab limestone, Supai formation, or Hermit shale. Gravelly limestone soils or sandy shale soils. North and east slopes and cool micro-sites next to stumps and logs. Great Basin conifer woodland (pinyon-juniper), sagebrush, Great Basin Desert shrub, Mohave Desert shrub.

Flagstaff beardtongue (Penstemon nudiflorus)

4500-7000’. Found south of the Grand Canyon and in Sycamore Canyon. Dry slopes in eroded or mountainous terrain. Kaibab limestone or sandstone. Rock outcrops or shallow soils, coarse loamy, neutral pH. Ponderosa pine, Gambel oak, alligator juniper, blue grama.

Grand Canyon rose (Rosa

stellata ssp. abyssa)

4500-7500’. Found near the Grand Canyon. Potential habitat occurs at Marble Canyon and Kanab Creek Canyon on the N Kaibab RD. Canyon rims and cliff tops, low ledges at depressions, edges of mesas and plateaus, or in shallow drainages. Kaibab limestone or in breccia pipes where uranium prospects have been concentrated. Gravelly red clay soils. Full sun. Great Basin Conifer Woodland and Great Basin Desert scrub with singleleaf pinyon, Utah juniper, and big sagebrush.


Table XIV. Special-Status Plant Species that May Occur in or near the Project Areas

Species Name Status* Habitat Potential for Occurrence in Project Area

Mt. Dellenbaugh sandwort (Arenaria aberrans)

USFS Sensitive

Sandy soils in oak and pine forests.

No impacts to habitat or population trends; not known to occur in the project area. Potential areas of habitat occur in Bozo and Grandpa. Species is evaluated in detail in the effects section.

Tusayan rabbitbrush (Chrysothamnus molestus)

USFS Sensitive

Grows on calcareous soils derived from limestone and basalt parent material, typically found in open pinyon-juniper grasslands on slopes and flats.

May occur; habitat is present on the Tusayan RD and plant populations have been found near these sites. This species are analyzed in detail in the following

section. . Known to occur within 5 miles

of the project area, potential to occur at all sites except Sze. Species is evaluated in detail in the effects section.

Arizona leatherflower (Clematis hirsutissima)

USFS Sensitive

Rocky hillsides and cracks in cliff faces within ponderosa pine forests.

No impacts to habitat or population trends; not known to occur in the project area. Potential areas of habitat occur in Garfield, Maybe and Sze —not known to occur in the project area. Species is evaluated in detail in the effects section.

Flagstaff pennyroyal (Hedeoma diffusa)

USFS Sensitive

Open spots in ponderosa pine forests.

No impacts to habitat or population trends; not known to occur in the project area. Suitable habitat is present. Potential areas of habitat occur in Garfield, Maybe and Sze —not known to occur in the project area. Species is evaluated in detail in the effects section.

Flagstaff beardtongue (Penstemon nudiflorus)

USFS Sensitive

Dry ponderosa pine forests, mountainous regions south of Grand Canyon 4,500 to 7,000 feet.

No impacts to habitat or population trends; not known to occur in the project area. Suitable habitat is present. Potential areas of habitat occur in Garfield, Maybe and Sze —not known to occur in the project area. Species is evaluated in detail in the effects section.

*Status definitions:

E = Federally listed as Endangered under the Endangered Species Act (ESA). C = Federally designated as Candidate for listing. USFS Sensitive = On KNF Sensitive Species list.

Wildlife Biology

This section describes the wildlife resources present within areas within lands covered by the Proposed Plan of Operations. Animal species listed under the Endangered Species Act of 1973 (ESA); animal species classified as Sensitive by the Southwest Region (R3) of the U.S. Forest Service (USFS); Kaibab National Forest (KNF) Management Indicator Species (MIS); and migratory bird species are described. Big game species are discussed in the section on MIS.


Species listed under the Endangered Species Act Animal species listed under the Endangered Species Act (ESA) and identified for Coconino County, Arizona by the U.S. Fish and Wildlife Service (USFWS 2008) were evaluated (Table XV). The list includes species classified as Candidate or Proposed and species with conservation agreements. The project area is outside of known ranges or

lacks suitable habitat for each species.

Critical habitat for the Mexican spotted owl (MSO) is located in the steep-walled canyons below the rim of the Grand Canyon and not on lands administered by the Kaibab National Forest. There is no habitat for MSO and none are known to occur in the project

vicinity.

Table XV. Wildlife Species Listed under the Endangered Species Act and Identified for Coconino County, Arizona by the U.S. Fish and Wildlife Service

Common Name Scientific Name

Status

Arizona Range and Habitat

Invertebrates Kanab ambersnail

Oxyloma haydeni

kanabensis

Endangered

Few small, isolated populations: one in Utah and one in Grand Canyon National Park. Travertine seeps and springs.

Fish Apache trout

Oncorhynchus

apache

Threatened

Native to White Mtns, introduced population in North Canyon Creek on North Kaibab District. Cold mountain streams with low gradient meadow reaches.

humpback chub Gila cypha Endangered Colorado and Little Colorado Rivers. Critical Habitat in Grand Canyon.

little Colorado spinedace

Lepidomeda vittata Threatened Critical habitat in East Clear Creek, Chevelon Creek, and Nutrioso Creek.

razorback sucker Xyrauchen texanus Endangered Critical Habitat includes portions of Colorado, Salt, and Verde Rivers.

Amphibians Chiricahua leopard frog

Rana chiricahuensis

Threatened

Montane central AZ east and south along Mogollon Rim and southeast AZ. Requires permanent or near permanent streams, rivers, ponds, or stock tanks free from introduced fish, crayfish, and bullfrogs.

Birds California brown pelican

Pelecanus

occidentalis

californicus

Endangered

No breeding records in AZ. Uncommon transient on lakes and rivers.

California condor

Gymnogyps

califorianus

Endangered

Reintroduction of birds classified as Experimental Nonessential Population to northern AZ began in 1996. Common in Vermillion Cliffs and Grand Canyon.

Mexican spotted owl

Strix occidentalis

lucida

Threatened

Patchily distributed in canyons and dense, multi-age forests between 4,100-9,000 feet. Critical habitat designated in mixed conifer and pine-oak forests on portions of Kaibab NF.


southwestern willow flycatcher

Empidonax traillii

extimus

Endangered

Cottonwood/willow and tamarisk vegetation communities along rivers and streams.

yellow-billed cuckoo

Coccyzus

americanus

Candidate

Large blocks of riparian woodlands (cottonwood, willow, or tamarisk-dominated habitats).

Mammals black-footed ferret

Mustela nigripes

Endangered

Individuals classified as Experimental Nonessential Population reintroduced into Aubrey Valley in western Coconino County in 1996. Grasslands with large prairie dog colonies.

Forest Service Sensitive Species

Of the species listed in Table XVI, the species that may have potential habitat in the project area include the Allen’s lappet-brown bat, bald eagle, desert elfin, northern goshawk, Merriam’s shrew and Mogollon vole.

Table XVI. Species from the 2007 Southwestern Region (R3) Forest Service Sensitive Species List whose Range Overlaps the Williams or Tusayan Ranger

District.

Species

Distribution and Habitat

northern leopard frog

Rana pipiens Northern and central Arizona. Permanent water with rooted aquatic vegetation and adjacent wet meadows. Historically occurred on Williams District but no known current populations.

bald eagle

Haliaeetus leucocephalus No known nests on Kaibab NF. Primarily a winter resident/migrant on both districts. Feeds primarily on fish, waterfowl, and carrion.

northern goshawk Accipiter gentilis

Nests primarily in ponderosa pine forests on both districts. Feeds on wide variety of birds and small to medium-size mammals.

burrowing owl Athene cunicularia

Open well-drained grasslands, steppes, deserts, prairies, and agricultural lands, often associated with burrowing mammals. No known populations on either district.

American peregrine falcon

Falco peregrinus Nests on cliffs and rock outcrops. Preys on birds. Past nest sites known from Bixler and Sitgreaves Mountains on Williams District.

Merriam’s shrew

Sorex merriami Found in dry, montane coniferous forests. Known to occur in ponderosa pine forests and pinyon-juniper woodlands on Tusayan and Williams Districts.

spotted bat Euderma maculatum

No records on Williams District, but known to occur on Tusayan District and in Grand Canyon. Occurs in wide variety of habitats, including ponderosa pine forest. Roosts in crevices and cracks in cliff faces and rock outcrops.

Allen’s lappet-browed bat Known to occur on Williams and Tusayan Districts. Common in


Species

Distribution and Habitat

Idionycteris phyllotis ponderosa pine forest but also occurs in forest and woodland types. Roosts behind sloughing bark in large, old ponderosa pine snags.

Townsend’s big-eared bat Corynorhinus townsendii

Occurs in desertscrub, oak woodlands, pinyon-juniper, and conifer forest types throughout state in summer. Occurs primarily south of Mogollon Rim in winter. Uses caves, mines, and buildings as roost sites.

Mogollon vole Microtus mogollonensis

Occurs on both districts. Found in grassy areas within or near ponderosa pine, mixed conifer, spruce-fir, and aspen forest types and pinyon-juniper woodland.

Allen’s lappet-browned bat ranges from the central highlands of Mexico into west central New Mexico and across much of Arizona. It is not known from the southwestern deserts of Arizona and most specimens in Arizona have been taken from the southern Colorado Plateau, Mogollon Rim or adjacent mountain ranges. It is known to occur on the Williams and Tusayan Ranger Districts. Both woodlands and ponderosa pine forests containing snags with roost sites for bats exist in the project area. The bald eagle breeds from central Alaska, across much of Canada, south to the Great Lakes and Maine, and along the Pacific coast from the Aleutians to Baja. It also breeds along the Rocky Mountains and in central Arizona and northern Sonora. It is a resident along the Gulf coast from Texas to Florida and north along the Atlantic coast to New Jersey. Breeding birds require an adequate supply of moderate to large sized fish for prey, nesting sites (usually large trees or cliffs within a kilometer of water) and a lack of disturbance during the nesting period. An estimated 200-300 bald eagles winter in Arizona. Though no nesting habitat exists in the project area for the bald eagle, ponderosa pines in the area do provide winter roosting sites. No large stick nests were observed

during surveys on November 15 and 23, 2008.

Desert elfins are known from southeastern California, southern Nevada, central Utah, southwest Colorado, northern Arizona, and northwestern New Mexico. In northern Arizona it has been found in desert mountains and pinyon-juniper woodlands. The caterpillar host plant is cliffrose. Potential habitat for this species occurs in the Bozo,

Grandpa and Two Squares sites.

Goshawks breed in the northern hemisphere from timberline in Alaska and Canada south to Mexico and Pennsylvania and from timberline in Scandinavia and Siberia south to Morocco, Iran, Tibet and Japan. Mature conifers and cottonwoods are the primary nest trees for goshawks in Arizona. (AGFD1997). Goshawks occupy a wide diversity of forest and woodland habitats, but typically they nest in areas with relatively dense forest structure dominated by large diameter trees. Though many of the ponderosa pine that occur in the project area are large diameter trees, forest and woodland structure throughout the area is generally open. Goshawk habitat exists in both the Sze and Maybe

sites. There are existing post fledgling areas (PFA) within the Maybe and Sze sites.


Nesting areas occur within one mile of the Maybe site and within one-quarter mile of the

Sze site. Abert’s squirrels are a common source of prey for the northern goshawk. No

large stick nests, squirrel nests or squirrel sign were observed during surveys on

November 15 and 23, 2008.

Merriam's shrew has been found from Washington state to Montana, southward to Arizona and New Mexico and westward through Nevada into the eastern edge of California. It occurs most often throughout much of this range in sagebrush steppes though it is also known to occur in grasslands, pine forests and woodlands. Potential

habitat for this species occurs scattered throughout the project area.

Unlike most other small rodents, the Mogollon vole is active day and night, year-round. Habitat for Mogollon vole includes prostrate shrub thickets that provide dense cover, in areas with high litter and bare ground. It is also found in dry, grassy areas, usually adjacent to ponderosa pine forests, occasionally in juniper woodlands or stands of sagebrush, or in higher elevation spruce-fir forests. Elevation for this species on the KNF is 3,800 to 9,700 feet. Potential habitat for this species occurs scattered throughout the

project area.

Management Indicator Species

The seven MIS that are associated with habitat found in the project area are northern goshawk, wild turkey, hairy woodpecker, juniper titmouse, mule deer, elk and Abert’s squirrel (Table XVII).

Table XVII. Faunal MIS Species on Kaibab National Forest

Common Name Scientific Name Habitat Description

Invertebrates Aquatic macroinvertebrates

Includes mayflies, stoneflies, and caddisflies

Perennial streams and other perennial water bodies.

Birds Cinnamon teal Anas cyanoptera North and South Kaibab: ponds, lakes, and tanks with wetland

habitat. Northern goshawk Accipiter gentilis North and South Kaibab: ponderosa pine, mixed conifer, spruce-fir,

and aspen forests. Wild turkey Meleagris gallopavo North and South Kaibab: ponderosa pine, mixed conifer, aspen

forests; pinyon-juniper woodland. Mexican spotted owl Strix occidentalis lucida South Kaibab: mixed conifer forests. airy woodpecker Picoides villosus North and South Kaibab: ponderosa pine, mixed conifer, spruce-fir,

and aspen forests; pinyon-juniper woodlands. Red-naped sapsucker Sphyrapicus nuchalis North and South Kaibab: aspen forests. Juniper titmouse Baeolophus ridgwayi North and South Kaibab: pinyon-juniper woodlands. Pygmy nuthatch Sitta pygmaea North and South Kaibab: ponderosa pine forests. Lincoln's sparrow Melospiza lincolnii High-elevation wet meadows and willow-dominated riparian

habitats. Lucy's warbler Vermivora luciae Desert and other low-elevation riparian habitats. Yellow-breasted chat Icteria virens Low-elevation riparian habitats with well-developed shrub layer.

Mammals Elk Cervus elaphus South Kaibab: all forest and woodland habitat types on savannahs

and grasslands. Mule deer Odocoileus hemionus North and South Kaibab: all forest and woodland habitat types on

savannahs and grasslands. Pronghorn Antilocapra americana North and South Kaibab: grasslands, savannahs, and open forests. Red squirrel Tamiasciurus hudsonicus North and South Kaibab: mixed-conifer and spruce-fir forests. Abert's squirrel Sciurus aberti North and South Kaibab: ponderosa pine forests.


Goshawks are associated with late seral ponderosa pine and have been discussed under the Forest Service Sensitive Species section. Wild turkey are associated with a variety of forest or woodland types, but were chosen as a MIS species to represent late-seral ponderosa pine forests. They have inhabited Arizona since pre-Columbian times. Arizona is one of the few states that can boast wild turkeys of pure historic lineage (Phillips et al. 1964). Roosting and nesting habitat consists of large, open-crowned trees, often on steep slopes (Corman and Wise-Gervais 2005). Good brood rearing habitats include natural or man-made openings, plentiful herbaceous vegetation adjacent to forest cover, riparian areas, and mid-day loafing and roosting areas. Large woody debris is also used as cover (DeGraff et al. 1991). Wild turkeys feed on ponderosa pine cones, acorn mast from oak trees, seeds from grasses and forbs and invertebrates. Hairy woodpeckers are one of the most abundant primary cavity nesters in northern Arizona. This species was chosen as a MIS to represent the snag component of ponderosa pine, mixed conifer and mixed conifer with aspen habitats. They are found in Canada and central Alaska near the northern limit of boreal forest, south to Panama and northern Baja California, and east to the northern Bahamas Islands (Parker, 1987 and American Ornithological Union 1998). These birds are non-migratory. As primary cavity nesters, they depend on dead or dying parts of live trees and snags for nesting. Insects from the surface and subsurface of trees are their primary food source. They also eat a variety of fruits and seeds. They are often found at higher densities in recently burned areas, presumably due to the increased abundance of insect prey attracted to the burned trees. The juniper titmouse is a pinyon-juniper obligate that selects mid-density stands of trees. It typically nests in natural cavities such as knot holes or broken branches but will also use cavities southeastern Oregon, northeastern Nevada, southeastern Idaho, southern Wyoming, central Colorado, and extreme Oklahoma south to southeastern California (east of the Sierra Nevada) central and southeastern Arizona, extreme northeastern Sonora, southern New Mexico and extreme western Texas (AOU 1998). In Arizona it is a fairly common to common resident in the northeastern, northern, central, and locally southeastern portions of the state (Latte et. al. 1999). The most abundant species of deer in Arizona is the mule deer. It is not limited to any one type of terrain and is found from sparse, low deserts to high, forested mountains. Mule deer generally prefer more rugged country. Deer are browsers and are known to feed on nearly 800 different plant species, including forbs, shrubs, trees, and grasses. Deer tracks were observed on the Two Squares site during surveys on November 15,

2008.

Elk are considered to be widespread and abundant globally, nationally and statewide. They are found year round on the South Kaibab National Forest. They generally prefer grasses to forbs for forage. In summer they occur in forests and mountain meadows. In winter they move to lower elevation pinyon-juniper woodland, conifer forest, and grasslands where they will browse woody shrubs (Bratland and others, 2008). Elk rubs,


tracks and/or droppings were observed at all sites during surveys November 15 and 23,

2008.

Abert’s squirrel live, nest and forage in ponderosa pine forests. Preferred habitat includes 9-18 inch diameter at breast height ponderosa pine trees, intermixed with larger trees, that provide groups of trees with interlocking crowns or crowns in close proximity to each other. Thickets of medium-sized trees with fewer large trees per acre also provide good habitat. Abert’s squirrels usually build their nests in the branches of large ponderosa pine trees, but also use cavities in Gambel’s oak and witches brooms. Though they depend heavily on the inner bark of twigs, seeds, terminal buds and male flowers of mature ponderosa pine trees for food, they often forage on the forest floor for roots, mycorrhizal fungi, carrion, bones and antlers (Nash and Seaman, 1977). Migratory birds Numerous migratory bird species occur in the project area. Most of the bird species considered above in the sections on Species Listed under the ESA, USFS Sensitive Species, and MIS are classified as migratory bird species. In addition, effects on Arizona Partners in Flight (PIF) Priority Species for Cold Desertscrub (Great Basin Desertscrub), pinyon-juniper woodland, and ponderosa pine habitat were evaluated (Latta et al. 1999), (Table XVIII). There are no designated Important Bird Areas near the project areas.

Table XVIII. Arizona Partners in Flight Priority Species

Common Name Scientific Name Ecological Factors

Pinyon-Juniper Habitat Gray flycatcher Empidonax wrightii Breed in semi-arid woodlands and brushy areas. Prefer large

pinyon-juniper stands with open understory and interspersed sagebrush, cliffrose, and barberry. Some ground cover is needed for insect foraging.

Pinyon jay Gymnorhinus cyanocephalus

Breeds in pinyon and ponderosa pine. Common in extensive stands of pinyon-juniper with open physiognomy.

Gray vireo Vireo vicinior Breeds in open mature pinyon-juniper woodlands on canyon and mesa slopes. Broadleaf shrubs generally present.

Black-throated gray warbler Dendroica nigrescens Primarily associated with pinyon-juniper woodlands and mixed oak-pine woodlands. Breeding habitat is characterized by a brushy understory. Foraging occurs at mid-canopy level by gleaning foliage and hovering for insects.

Juniper titmouse Baiolophus griseus Restricted to pinyon-juniper woodland vegetation type. Prefers a more open canopy.

Great Basin Desertscrub Habitat Sage thrasher Oreoscoptes montanus Breeding obligate of cold desertscrub.

Sage sparrow Amphispiza belli nevadensis

Commonly breeds in big sagebrush

Ponderosa Pine Habitat

Northern goshawk Accipiter gentilis in the southwest primarily use ponderosa pine and mixed conifer forests but have been documented in spruce-fir, Madrean oak woodland and pinyon-juniper woodland. Often associated with drainages, trails, primitive roads or small clearings.

Olive-sided flycatcher Contopus borealis in Arizona primarily associated with mixed conifer forests, subalpine forests with Engelmann spruce, and pure ponderosa pine forests. Snags are important as is a multi-level mature forest structure with fairly open canopy and “clumpiness”

Cordilleran flycatcher Empidonax occidentalis Breeding habitat includes spruce, fir, aspen, and pine forests, usually in moist shaded forests. Also uses hollows, canyon bottoms and riparian woodlands as well as rafters. Prefers dense canopy closure and/or drainages to create a cool microclimate


Purple martin Progne subis Generally prefer habitats near open water and inhabit open and cut over woodlands, open grassy river valleys, meadows around pools, shores of lakes, marsh edges, agricultural lands, saguaro deserts, parks and towns. Areas with high snag density adjacent to or in open areas are preferred in Arizona pine forests.

Plains Grassland Habitat

Swainson’s Hawk Buteo swainsoni In Arizona, found in open grassland habitat, open desertscrub with a grassland component, and open agricultural lands (Glinski and Hall, 1998). Nest more commonly in basin and range grasslands in southeastern Arizona than on Colorado Plateau. Builds stick nests in scattered lone trees within grassland or agricultural lands, in woodlands or in deciduous trees along stream courses (England and others, 1997).

Ferruginous hawk Buteo regalis Habitat includes grassland, shrub-grassland, shrubland and pinyon-juniper woodland. Nests may be built on ground, in a cliff or tall tree

Burrowing owl Athene cunicularia Found in open, dry grasslands, agricultural and range lands, and desert habitats associated with burrowing mammals (Haug and others 1993). Also found in grass, forb and open shrub stages of pinyon pine and ponderosa pine (Zeiner and others 1990)

Grasshopper sparrow Ammodramus savannarum

Prefers pure grassland habitat without trees or emergent shrubs (Bock and Bock 1988). Nests on ground with rim flush with ground level to be concealed by overhanging grass or forbs.

PIF species found in cold desertscrub habitat types include the sage thrasher, sage sparrow and Brewer's sparrow. Sage thrashers are cold desertscrub obligate breeders, but otherwise use the habitat as generalists. (Wiens and Rotenberry 1981). Sage sparrows are closely associated with pure stands of big sagebrush throughout their range (Rich 1978, Rotenberry and Wiens 1978, Wiens and Rotenberry 1981) or with big sagebrush stands mixed with bitterbrush, saltbush, shadscale, rabbitbrush or greasewood (Martin and Carlson 1998). These shrub habitats are usually semi-open and evenly spaced (Martin and Carlson 1998). The Brewer's sparrow breeds exclusively in cold desertscrub, primarily sagebrush, but also breeds in saltbush, shadscale and greasewood (Wiens and Rotenberry 1981, Medin 1990). No PIF species for cold desertscrub were detected

during field investigations.

PIF species found in pinyon-juniper woodland habitat types include the gray flycatcher, pinyon jay, gray vireo, black-throated gray warbler, and the juniper titmouse. Gray flycatchers select larger stands of pinyon and juniper with an open understory, often with sagebrush or greasewood. Pinyon jays are commonly found in extensive stands of pinyon and juniper with an open physiognomy. The gray vireo prefers open pinyon-juniper stands interspersed with broad-leafed shrubs. The black-throated gray warbler selects relatively taller, denser stands of pinyon-juniper. The juniper titmouse is a pinyon-juniper obligate that selects mid-density stands of trees. The only PIF species for pinyon

juniper woodland detected during field investigations was the pinyon jay, detected on

Two Squares, Garfield and Maybe sites.

PIF species found in ponderosa pine habitat include the northern goshawk, olive sided flycatcher, cordilleran flycatcher and purple martin. Goshawks are associated with late seral ponderosa pine and have been discussed under the Forest Service Sensitive Species section. Olive sided flycatchers breed in open montane and boreal coniferous and coniferous-deciduous forests, especially with abundant dead trees (Ehrlich, et al. 1988). Cordilleran flycatchers breed in deciduous and coniferous forests and woodlands, especially near water (Ehrlich et al., 1988). Purple martins nest in tree cavities excavated


by woodpeckers but will also use cliff habitat, eaves of buildings, birdhouses or other appropriate cavity types. No PIF species for ponderosa pine were detected during the

surveys.

Other avian species detected during the November 2008 surveys include the American

robin, common raven, dark eyed junco, mountain chickadee, Stellar’s jay, Townsend’s

solitaire, western bluebird and white breasted nuthatch.

Range, Noxious, and Invasive Exotic Weeds

This section briefly describes range resources, and noxious and invasive exotic weeds on the Kaibab National Forest (KNF), especially in lands covered by the Proposed Plan of Operations. Noxious and invasive exotic weeds Noxious and invasive exotic weeds found on the Tusayan Ranger District include: cheatgrass (Bromus tectorum), Dalmatian toadflax (Linaria dalmatica), diffuse knapweed (Centaurea diffusa), Scotch thistle (Onopordum acanthium), bull thistle (Cirsium

vulgare), and leafy spurge (Euphorbia esula). Some of these populations have been treated using manual, chemical, or biological control methods. Noxious weed monitoring, new treatments and re-treatments occur annually on the District.

Dalmatian toadflax occurs along Highway 64 in and around Tusayan. Cheatgrass occurs in many areas of the Tusayan District. It is expected that cheatgrass and possibly other invasive exotic weeds will expand their range within the boundaries of the recent X Fire during the spring and summer of 2009. These areas have large areas of bare ground and damaged soil surfaces that could provide sites for the establishment of invasive exotic weeds.

Mullein (Verbascum thapsus) and tumbleweed (Salsola iberica) were found in the November of 2008 field survey work in the Highway 64 right of way adjacent to the Sze site. Scattered tumbleweed were also observed at the Bozo and Grandpa sites, mostly associated with the existing access roads. Range resources The DIR sites are within the Anita grazing allotment (USFS 2004). The Anita and Cameron Allotments are under permit to one grazing permittee and are managed as one allotment. Information from the 2004 Environmental Analysis for the Anita, Cameron, and Moqui Allotments shows that range conditions have improved slightly on the Anita Allotment since the last analysis and the range trend is considered to be static to slightly upward. Changes in range management prescribed by the 2004 EA to improve range conditions have been implemented. There is one range monitoring cluster (RMCs) found at the DIR


Bozo claim site (K. Huling, 2008 personal communication) that should be avoided during all activities at this site.

Cultural Resources

Introduction

DIR Exploration, Inc., retained PaleoWest Solutions in Archaeology, Inc., to conduct a Class III inventory of six parcels for proposed uranium exploration and associated access roads in the Red Butte area of the Tusayan Ranger District, Kaibab National Forest. Each drill pad under the Proposed Plan of Operations would impact an area approximately 50 by 90 feet. Additionally, access via either existing roads, roads to be improved, or cross-country routes will be needed. Although these represent the only direct-impact areas, the Kaibab National Forest identified the entire area of each claim and a 100-foot corridor along each access route as the project’s Area of Potential Effect (APE), as the term applies to Section 106 Consultation under the National Historic Preservation Act of 1966. Each prospect had been covered to some degree by previous archaeological surveys, work that is covered in four separate archaeological reports prepared between 1985 and 1999. Because the Kaibab National Forest deemed these surveys outdated, they were and resurveyed in November 2008.

American Indian Consultations

Not covered in this Draft Environmental Analysis and its attention to cultural resources are consultations with the Havasupai, Hopi, Hualapai, Navajo, and Zuni American Indian tribes with known ties to the general area. Largely confidential consultations with appropriate members from each tribe by the USFS with regard to the Proposed Plan of Operations and its potential effects on historic and present day traditional uses will help determine what, if any, mitigation measures would be required in order to satisfactorily minimize or avoid creating negative effects on matters of concern to the named tribes. Consultation about these historic and present day traditional uses is governed and/or mandated by the National Historic Preservation Act, the American Indian Religious Freedom Act of 1978, the Native American Graves Protection and Repatriation Act of 1990, and Executive Order 13007 of 1996.

Culture History

Archaeologists have generally subdivided this area into five major periods: the Paleoindian period (9500–6500 B.C.), the Archaic period (6500 B.C.–A.D. 500), the Formative period (A.D. 500–1300), the Protohistoric period (A.D. 1300–1540), and the Historic period (A.D. 1540-present). Fairley (2003:Table 2) has divided the culture history of the Grand Canyon into five major periods: Archaic, Formative, Protohistoric, and Historic.


Paleoindian period The Paleoindian period was a time when peoples of the Southwest subsisted by hunting now-extinct large mammals using distinctive lanceolate projectile points. During the Clovis period (9500–8800 B.C.), they hunted mammoths, primarily, using fluted Clovis points. During the Folsom period (circa 8800 B.C.), they hunted long-horned bison, primarily, using fluted Folsom projectile points. During the late Paleoindian period (circa 7500–6500 B.C.), they hunted modern bison, primarily, using a number of unfluted, lanceolate projectile points (Geib 1996:7). Archaic period The Archaic period began about 6500 B.C. and lasted until about A.D. 500 in the Grand Canyon. The Archaic period was a time when the subsistence strategy was based on the hunting of modern species of animals and the gathering of wild plants (Ahlstrom et al. 1993:69). Recent archaeological surveys on the rims of the Grand Canyon have documented an extensive Archaic. Hunter-gatherers are generally organized as mobile bands exploiting large territories, although Archaic subsistence, social, and settlement systems in this region have not been comprehensively investigated. The Archaic period provides the first evidence for ritual in the Grand Canyon region. Occupation during this time was first recognized when split twig figurines were found in caves containing the bones of an extinct mountain goat (Euler 1966). Formative period Archaeologists recognize three Formative period cultural traditions in this region: the Kayenta Anasazi, the Virgin Anasazi, and the Cohonina (Fairley 2003). The Kayenta Anasazi were centered east of the Grand Canyon, on Black Mesa, the Shonto Plateau, and the Rainbow Plateau. Their dwellings ranged from pit houses to large masonry pueblos. They manufactured Tusayan Gray Ware, Tusayan White Ware, and Tsegi Orange Ware. The Virgin Anasazi were centered at the confluence of the Virgin River and the Colorado River. Much of their gray ware and white ware pottery was almost indistinguishable from Kayenta pottery, but they made Moapa Gray Ware and Moapa White Ware. Populations along the North Rim of the Grand Canyon on the Kaibab and Kanab plateaus manufactured local pottery traditions (Shinarump and Shivwits). The Cohonina were centered on the south side of the Grand Canyon. Architecture included masonry pueblos and pit houses, but the Cohonina did not construct kivas. They made San Francisco Mountain Gray Ware (Ahlstrom et al. 1993:73–74).A fourth tradition, the Cerbat, may have its origins in the Formative period. The Cerbat archaeological tradition is generally considered ancestral to the modern Pai. Cerbat sites, which are not common, are recognized based on the presence of Tizon Brown Ware. Protohistoric period The period from about A.D. 1300 to A.D. 1540, when the Spanish entered the area, is referred to as the Protohistoric period. Hualapai, Havasupai, and Paiute use of the area was a hunting-and-gathering adaptation supplemented by agriculture (Ahlstrom et al.


1993:82). Although some locations were occupied year after year, dwellings were impermanent wickiups that were rebuilt each year. The Pai groups manufactured Tizon Brown Ware and also made notched triangular projectile points. The Paiute manufactured Southern Paiute Utility Ware. Like many protohistoric groups across the Southern Plains and the Southwest, the Paiute manufactured Desert Side-Notched projectile points Even as Puebloan peoples ceased to occupy farming villages in the Grand Canyon, the Hopi villages on southern Black Mesa were forming, and the Hopi continued to use the Grand Canyon, most notably making pilgrimages there and collecting salt (Titiev 1944). The presence of Hopi Yellow Ware at Grand Canyon sites indicates that the Hopi also continued to visit or trade with the peoples residing at the Grand Canyon. Historic period In 1540, the Coronado Expedition sent two exploring parties to the Hopi pueblos and in 1629, the Spaniards established missions at the Hopi pueblos, and these were in use until the Pueblo Revolt of 1680. In the summer of 1776, Tomás Garcés visited Havasupai during his missionary trip from Yuma to Hopi (Coues 1900). Later in 1776, the expedition of Franciscan fathers Silvestre Vélez de Escalante and Francisco Atanasio Domínguez passed to the north and east of Grand Canyon while searching for a direct route between New Mexico and California (Vélez de Escalante [1776] 1995). Following Mexican independence in 1821, French, English, and American trappers began infiltrating the region, familiarizing themselves with the geography and Native American travel routes (Hughes 1978). After acquiring new lands in the Southwest from Mexico in 1848, the U.S. government sent numerous American military expeditions to explore and map land and water routes through the Southwest territories during the 1850s and 1860s (Anderson 1998). During the 1850s, Mormon homesteaders began pushing southward into northern Arizona from their communities in Utah, and by the 1860s, cattle ranchers and sheepherders had entered the region, mainly grazing their herds on the more suitable vegetation of the North Rim. Prospectors began probing the Canyon for copper, gold, and other mineral deposits by the 1860s. Mining has also been historically important to this region. The encroachment of ranchers, miners, and lumbermen triggered conflicts with the local Native American populations over control and access to various resources. Completion of the Atlantic and Pacific Railroad’s transcontinental route through northern Arizona in 1883 combined with various federal settlement and reclamation programs to accelerate the economic growth and development of the region (Anderson 1998).

Previous Research

Prior to fieldwork, a site records search was conducted at the Supervisor’s Office at the Kaibab National Forest in Williams, Arizona on November 12, 2008. The records indicated that four previous surveys had been conducted in the proposed project area for earlier uranium prospects and timber sales. The records search also revealed that 11 previously recorded sites were located within the project areas.


Cartledge’s 1985 survey of the area for the Miller Seep and the Gallo timber sales covered approximately 3025 acres, with portions of that survey overlapping the current project areas. Carledge (1985) documented 64 archaeological sites, six of which lie within the current project area. Five sites are located within the Garfield prospect (521, 523, 524, 526, 527) and one within the Maybe prospect (589). Wigglesworth and Geib’s 1987 survey for DIR Exploration, Inc. covered sections of the Bozo, Garfield, Maybe, Grandpa, and Sze prospects. This survey uncovered three new archaeological sites in the Garfield (699), Grandpa (700), and Maybe (696) prospects. Hammack (1992) conducted a survey in 1992 of four proposed uranium prospects for DIR Exploration, Inc, three of which overlap the current project area. This surveyed covered five acres in each of the Grandpa, Two-Squares and Sze prospect, relocated one previously recorded archaeological site (700) in the Grandpa prospect and found one new archaeological site (1151) in the Sze prospect. In 1999, Weintraub (1999) surveyed the majority of the Sze prospect as part of a post and pole sale of 563 acres near the Grand Canyon airport and relocated site 1151, but discovered no other cultural resources within the project area.

Survey Methods

The fieldwork was carried out between November 13 to 19, 2008 by Paleowest Project Directors, Jeremy Omvig (M.A., RPA) and Jaclyn Mullen (M.A., RPA). Ground visibility generally ranged from good in standing pinyon-juniper and ponderosa forests to excellent. However, some areas did have thick vegetation and pine duff coverage resulting in poor visibility during the archeological surveys.

Prior to fieldwork, DIR Exploration, Inc. had flagged both the corners and boundaries of each prospect, in addition to supplying Paleowest with an Excel spreadsheet with the project area coordinates. Transect spacing between archaeologists was maintained at 15 meters through the use of two GPS units supplemented by a compass. Each prospect was covered in systematic north-south or east-west transects. UTM coordinates for site and isolated find locations were recorded both in GPS units (using the NAD83 datum) and on field forms so that the data were maintained in duplicate locations. Isolated finds were photographed with a digital camera.

When a site was encountered, the crew spread out with pink flagging tape to mark site boundaries and features. A prominent tree was selected as the site datum, but was not marked with a datum tag (as per the suggestion of the Forest Service archaeologist). The boundaries of the site were marked with pink flagging tape. No collections were made.

New site information was documented on printouts provided by the Forest Service that was later uploaded into the heritage resource database managed by the Kaibab National Forest in Williams, Arizona. Each new site was mapped, digitally photographed, and assessed for National Register eligibility. In addition, shapefiles were created in Arc-GIS for each newly discovered archaeological site and one previously recorded site and the survey areas, which were sent to the Supervisor’s office of the Kaibab National Forest in Williams, Arizona to be uploaded into the GIS database. The site datum was established, and a GPS coordinate and elevation reading for the datum was recorded on site maps, field forms, and the Forest Service printouts.


Survey Results

The survey work relocated ten of the eleven previously recorded archaeological sites in the project area. These sites were relocated, re-recorded and re-mapped when necessary. Several of the sites needed updated UTM coordinates and one site (700) required an increase in the site boundaries. Five new sites were discovered and ten isolated finds were recorded. The following provides the results of the survey work for each prospect. Bozo prospect The Bozo prospect is located on the Red Butte (35112-G1) USGS 7.5’ quadrangle map in the SE ¼ of Section 12, Township 28 North, Range 4 East. The prospect is located approximately seven miles east of Highway 180/64 off Forest Service Road 320 and covers 40 acres. The predominant vegetation in the Bozo prospect is Pinyon-juniper. A significant drainage runs north-south through the center of the prospect and feeds into Stem Wash approximately 1 mile south of the project area. The periphery of the prospect consists of flat hilltops that slope into the drainage. In 1985, Wigglesworth and Geib surveyed 8.2 acres of the prospect and found no cultural resources. The current survey discovered one new archaeological site (1877) and two isolated finds. Table XIX provides a summary of the archaeological sites in the Bozo Prospect and Table XX summarizes the isolated finds.

Table XIX. Summary of Sites Located in the Bozo Prospect

Site Number AR-03-07-04-

Description Temporal Affiliation NR Recommendation

1877 Kaibab Chert Quarry Unknown Prehistoric Eligible (D)

Table XX. Summary of Isolated Finds Discovered in the Bozo Prospect

Isolated Find # Description

8 Five primary flakes of Kaibab chert located on a flat hilltop above drainage

9 One Kaibab chert scraper located a flat hilltop overlooking drainage

Garfield prospect The Garfield prospect is located on the Red Butte (35112-G1) USGS 7.5’ quadrangle map in the NE ¼ of Section 26, Township 29 North, Range 3 East. The prospect covers 60 acres and is accessible from Forest Service Road 304, which runs through the project area. The predominant vegetation coverage in the prospect is open ponderosa pine forest. The entire prospect had been covered by previous surveys (Wigglesworth and Geib 1987) and six previously recorded sites were located in the prospect, all of which were relocated and reevaluated. In addition, one new site (1878) was also discovered. No isolated finds were recorded. Table XXI describes the seven sites, their temporal affiliation, and National Register eligibility.


Table XXI. Summary of Sites Located in the Garfield Prospect



521 Lithic/Ceramic Scatter Pueblo II (AD 900-1100) Ineligible

523 Lithic/Ceramic Scatter Pueblo II (AD 900-1100) Eligible (D)

524 Lithic Scatter Unknown Prehistoric Eligible (D)

526 Lithic Scatter Unknown Prehistoric Eligible (D)

527 Lithic/Ceramic Scatter Pueblo I/II (AD 700-1100) Eligible (D)

699 Masonry roomblock with associated architecture and midden.

Pueblo II (AD 1050-1150) Eligible (D)


Grandpa prospect The Grandpa prospect is located on the Red Butte (35112-G1) USGS 7.5’ quadrangle map near the center of Section 6 Township 27 North Range 4 East. The prospect is located approximately nine miles east of Highway 180/64 off Forest Service Road 305. The predominant vegetation in the Grandpa prospect is Pinyon-juniper and open grassland. A draw encompasses the center of the prospect, which is surrounded by level terrain that slopes into the draw. The slopes of the hillsides are covered in limestone outcrops with abundant amounts of large Kaibab Chert nodules. The prospect’s survey area covered 40 acres, in addition to a mile long access road that runs from the northern end of the project area to Forest Service Road 305. In 1987, Wigglesworth and Geib surveyed 14 acres of the prospect and found one archaeological site (700), a large red Kaibab Chert quarry located at the center of the prospect. Table XXII. Summary of Sites Located in the Grandpa Prospect, provides a summary of the archaeological sites in the Grandpa Prospect and Table XXIII summarizes the isolated finds.

Table XXII. Summary of Sites Located in the Grandpa Prospect




Table XXIII. Summary of Isolated Finds Discovered on the Grandpa Prospect


6 50 brick red Kaibab Chert flakes plus one biface/preform. Likely represents one knapping episode associated with nearby site 03-07-04-700.

7 1 Government Mountain obsidian point base – Bajada (Archaic)


Maybe prospect The Maybe prospect is located on the Tusayan East (35112-H1) USGS 7.5’ quadrangle map near the center of Section 15, Township 29 North, Range 3 East. The prospect is located approximately six miles east of Highway 180/64 off Forest Service Road 516. The predominant vegetation in the Maybe prospect is open Ponderosa Pine forest. The Maybe survey area covered 60 acres and also included approximately 1500 feet of survey along existing Forest Service Road 516 for blading improvements. The majority of the Maybe prospect was previously surveyed, except for approximately 11 acres along the eastern and northeastern edges and small portion in the southwest corner and contained three previously recorded archaeological sites. Cartledge (1985) surveyed approximately 15 acres of the Maybe prospect and discovered site 589, a Cohonina ceramic and lithic scatter. In 1987, Wigglesworth and Geib surveyed 40 acres of the prospect, some of which overlapped with the Cartledge survey, and discovered site 696, a ceramic and lithic scatter. The current survey discovered no new archaeological sites and one isolated finds. Table XXIV provides a summary of the archaeological sites in the Maybe Prospect and Table XXV summarizes the isolated finds.

Table XXIV. Summary of Sites Located on the Maybe Prospect

(*indicates site not relocated during current survey)



058* Habitation Site Undetermined Unknown

589 Ceramic and Lithic Scatter


696 Ceramic and Lithic Scatter

Early Archaic and Basketmaker III (AD 700-900)

Eligible (D)

Table XXV. Summary of Isolated Finds Discovered on the Maybe Prospect


10 1 heavily reworked biface fragment of Kaibab Chert

Sze prospect The Sze prospect is located on the Tusayan West (35112-H2) USGS 7.5’ quadrangle map in the NW ¼ of Section 13, Township 29 North, Range 3 East . The prospect area covers 60 acres and transects Highway 180/64, with approximately 46 acres covering the west side of the highway and the remaining 14 acres on the east side. Currently, the drilling exploration is proposed only on the west side of the highway. The west side of the prospect is accessible off Forest Service Road 308 via an abandoned road. The east side


is most easily accessible via an access road off Forest Service Road 308 for a power line that parallels the highway, but lies outside the prospect boundaries. The predominant vegetation is open ponderosa pine forest. Limestone outcrops are present on the western side of the prospect; however, no major chert deposits were seen. In addition, the area near abandoned road was covered in at least two dozen limestone rock piles, which were recorded as an isolated find (IF2). Hammack (1992:13) noted these rock piles during his survey, but did not record them as an isolated find or site as they were all considered to be relatively recent and likely associated with copper exploration test pits. The area east of Highway 180/64 is the only portion of the Sze prospect not previously surveyed. On the west side of the highway, Hammack (1992) surveyed approximately five acres for DIR Exploration and located one new site, 1151, which is located just west of Highway 180/64. In 1999, Weintraub surveyed the entire prospect west of the highway and found no new cultural resources within the prospect boundaries, but did reassess site 1151. The current survey discovered two new archaeological sites (1874 and 1875) and two isolated finds. Both new sites are located on the east side of the highway and away from any proposed drilling exploration. Table XXVI provides a summary of the archaeological sites in the Sze Prospect and Table XXVII summarizes the isolated finds.

Table XXVI. Summary of Sites Located on the Sze Prospect.



1151 Limited Activity/Habitation


1874 Habitation Pueblo II/III (AD 900-1300)

Eligible (D)

1875 Habitation Pueblo III (AD 1100-1300) Eligible (D)

Table XXVII. Summary of Isolated Finds discovered in the Sze Prospect.


1 Screw top gas can lid, four church key beverage lids, one glass bottle jug top, three punch tin cans, and sheet metal located along the abandoned road.

2 Limestone rock piles likely associated with mining activities or test pits for copper deposits (Hammack 1992).


Two-Squares prospect The Two Squares prospect is located on the Red Butte (35112-G1) USGS 7.5’ quadrangle map in the NW ¼ of Section 30, Township 29 North, Range 3 East. The prospect is located approximately 1.5 miles east of Highway 180/64 off Forest Service Road 308. The survey area covered 40 acres, in addition to approximately 1500 feet of an access road. The vegetation coverage in the Two Squares prospect includes pinyon-juniper and ponderosa pine on the hill tops and slopes, while the center of the prospect is a clearing of sagebrush and grasses. Wigglesworth and Geib (1987) surveyed 28 acres of the prospect and found no cultural resources; however, mention was given to a large chert quarry north of the project area, which was not recorded. Hammack (1992:11) surveyed five acres and also mentioned a chert quarry that was located outside the 1992 project area boundaries. Neither survey recorded any cultural resources in the project area The current survey discovered one new archaeological site (1876) and three isolated finds. The new site represents the chert quarry that was mentioned, but not recorded during the previous surveys in the prospect. Table XXVIII provides a summary of the archaeological sites in the Two-Squares Prospect and Table XXIX summarizes the isolated finds.

Table XXVIII. Summary of sites located in the Two-Squares Prospect.




Table XXIX. Summary of Isolated Finds discovered in the Two-Squares Prospect


3 Pink Kaibab Chert Biface

4 Coffee can, condensed milk can, meat tins, beverage cans, Roma wine bottle, and glass food jar located in clearing next to a modern fire pit

5 9 Deadman’s Grey sherds in a 10 x 10 meter area

Socioeconomic Resources and the Environmental Justice Baseline

Coconino County

The following information was largely obtained from the August 2008 USFS report entitled, Kaibab National Forest Social and Economic Sustainability Report, which can be downloaded from http://www.fs.fed.us/r3/kai/plan-revision/forestplan.shtml, and from the 2005 Socio-Economic Assessment for the Kaibab National Forest, prepared for the


USFS by the University of Arizona School of Natural Resources. This last named report can also be downloaded from the website page cited above. The geographic area most affected by operations within the Tusayan Ranger District of the Kaibab National Forest is the region encompassed by Coconino County, Arizona. The Tusayan Ranger District is centrally located within the county. Coconino County includes the following:

• The towns and cities of Flagstaff, Sedona, Page, Williams, and Fredonia;

• Numerous small villages, unincorporated communities, and widely dispersed ranch and residential holdings; and,

• Parts of the Navajo, Hopi, and Hualapai Indian Reservations, and all of the Havasupai Indian Reservation.

Census year 2000 population for Coconino County was 116,320. In 2000, the total minority population percentage for the county was 36.9 percent. Since 1970, Coconino County has evidenced a population growth rate of about 2% per year. As is the case for most of Arizona, the population increase in individuals age 65 and over is greater than the increase of those 18 and under. Of all the states except Florida, Arizona has experienced the second highest net immigration of people over the age of 65 in the US. In Coconino County this segment of the population increased at approximately 4.6% per year between 1990-2000, while the under-18 segment only increased at annual average rate of about 1.3% per year. Three factors exacerbate this population aging trend in Coconino County: Effects of low median income, lack of workforce planning, and the high cost and/or lack of affordable housing have all motivated relatively young adults to avoid living in the County. Research shows that areas with mild climate, forested mountains, access to camping, and presence of clean air and water are attractive to retirement-age people as well as to other immigrants able to take advantage of the quality of life present in small, rural communities. Unfortunately, influx of relative newcomers to rural areas tends to automatically generate conflicts between the value systems of more native residents and recently arrived immigrants, especially conflicts over natural resource management matters. To quote University of Arizona, 2005 (p. 20): “Land management objectives of new property owners may lead to demands for change in how adjacent federally administered land is managed.” Increasing the potency of the effect of these members of immigrant populations in their new communities is their relative sophistication in understanding planning regulations, and greater familiarity with methods of influencing political processes. In 2000, median family annual income in Coconino County was $34,800 (1990 dollars) as compared to $30,600 (1990 dollars) in 1990. The 1990 average county poverty rate of 23.1% dropped materially to 18.2% by 2000. Poverty rates in Coconino County in 2000 were highest for American Indians (32%), followed by Hispanics (20%) and African-Americans (19%). Presumably, these high minority poverty rates reflect the combined effect of relatively high unemployment rates (i.e., seasonal, part-time, and/or permanent unemployment) and relatively low wages. Interestingly, 1990 census data show that


county-wide minority poverty rates were, overall, appreciably higher at that earlier date. For example, in the 1990 census, the Coconino County poverty rate for American Indians was 44.4% and 33.5% for African-Americans. Average rate of poverty within the White population of Coconino County, on the other hand, increased from 10.7% in the 1990 census to 12% in 2000. Williams is the closest example of a generic45, historically-archetypical northern Arizona town to the Proposed Plan of Operations in the Tusayan Ranger District. The 1990 constant dollar median family income of the residents of Williams dropped from $26,500 in 1990 to $23,400 in 2000, while the 1990 Williams poverty rate of 11.7% increased to 15.0% by 2000. See Table 6 of UA 2005 for additional information. Decrease in Coconino County rural incomes and increase in rural poverty rates over the 1990-2000 period, like those seen in the Williams area, were associated with an economic shift from the extractive industries of ranching, timber harvesting, and mining towards a greater economic emphasis on the service (especially tourism) and professional sectors. Consistent with the in-migration of retired people to Coconino County and the coincident growth of lower-paying service sector jobs (especially in tourism-related occupations), labor income in Coconino County grew more slowly than transfer (social security, pensions, and retirement) and dividend income. Overall, these economic shifts appear to have had the unintended effect of decreasing environmental justice within the more rural and off-reservation portions of Coconino County, and seem, surprisingly, to have most affected the low-income, rural population of the county not residing on reservation lands. 46 Dominant occupations of the Coconino County population are listed below in Table XXX. Approximately 28% of workers in Coconino County are employed in the tourism industry (Hjerpe and Kim, 2007, p. 141). This proportion is highest of all the counties in Arizona and results from the presence of the Grand Canyon, Page, Lake Powell, Sedona, Flagstaff, and Interstate 40 within the boundaries of the county. Reflecting the influence of low wage tourism jobs on the county economy, the average Coconino County wage in 2005 was 19 to 25 percent less than the US average. Furthermore, within the tourism industry, jobs in the food preparation and serving occupations paid barely half of

45 That is, a community not almost entirely supported by reliance on tourism and/or the educational industries like Tusayan and Flagstaff are. Given their space for new housing and water supplies, Williams, Parks and Valle would most likely be directly and most strongly impacted by the growth of the uranium mining industry in the Tusayan Ranger District. These communities and their populations are also the most economically disadvantaged in closest proximity to the Tusayan District. 46 As defined in UA 2005, “Environmental justice is the fair treatment of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. Fair treatment means that no group of people, including racial, ethnic, or socioeconomic groups, should bear a disproportionate share of the negative environmental consequences resulting from industrial, municipal, and commercial operations or the execution of federal, state, local, or tribal programs and policies. Inequities can result from a number of factors, including distribution of wealth, housing and real estate practices, and land use planning that may place African Americans, Latinos, and Native Americans at greater health and environmental risk that the rest of society [emphasis added].” A very relevant case of unintended adverse environmental justice effects also related to the “not in my backyard” impulses of the more privileged in US society has been detailed by Nordhaus and Shellenberger (2007) in their Chapter 3.


Coconino County’s low overall average wage figure (Arizona Department of Commerce, 2007). In addition to the weak wage structure of Arizona as a whole (UA 2005, p. 20) and Coconino County in particular, Arizona evidences very low industrial diversification, diversification that increased through the 1970s, peaked in the mid-1980s, and has now fallen well below that of most other states. Highly diversified economies like those contained in neighboring Utah have been observed to recover much more quickly from economic recessions than poorly diversified economies like that of Arizona.47 According to Hjerpe and Kim (2007, p. 141-142), “Jurisdiction issues, poverty, and a lack of a diversified economy contribute to a turbulent social and economic atmosphere in the greater Grand Canyon region and justify economic development research and planning.”48

Table XXX. Dominant Occupations of the Coconino County Population in 2000 (UA 2005)

Occupations Number Percent Management, professionals, & related occupations 19,309 38.4%

Sales and office occupations 14,240 25.7%

Service occupations 10,610 19.1% Construction, extraction, & maintenance occupations 5,548 10.0%

Production, transportation, and material moving occupations 5,529 10.0%

Kaibab National Forest Economic Contributions

Current (2006) total estimated direct and indirect contributions of Kaibab National Forest resource programs on the area economies including Coconino, Yavapai, Mohave, Washington (UT), and Kane (UT) counties are shown in Table XXXI below (USFS 2008, pp. 30-31). According to these data, the Kaibab National Forest minerals program stimulates the highest amount of employment and labor income related directly and indirectly to the Kaibab National Forest public lands, with government expenditures by the USFS itself coming in second.

47 This economic truism has been recently been refined. See page 155, this report. 48 Interestingly, it can easily be argued that it is exactly this regional ferment described by Hjerpe and Kim that created the impetus for this NEPA planning document. This particular predictive association suggests that the Hjerpe and Kim model of the Grand Canyon region socioeconomic system is accurate.


Table XXXI. Economic Effects of KNF Lands Management Activities, Coconino County

Resource Program contributions to 2006 labor income ($)

Program contributions to 2006 employment (job #s)

Recreation $3,445,000 127

Wildlife and fish 863,000 31

Grazing 311,000 21

Timber 2,046,000 81

Minerals 18,600,000 536

Pmt’s to State/Counties 2,068,000 67

Total KNF-derived Product

$27,333,000 863

Total KNF USFS Expenditures & Labor

$15,445,000 314

USFS KNF Apparent Multipliers

1.77 2.75


Chapter 4. Environmental Effects

Introduction

This chapter relates the expected environmental effects of the Proposed Plan of Operations and contrasts these expected effects with the expected results of the No Action Alternative in which the Proposed Plan of Operations is not approved and the Kaibab JV exploration work is not carried out. This chapter reviews the expected effects of the Proposed Plan and the No Action Alternative on each pertinent facet of the environment in the same order as these facets were considered in Chapter 3 of this report.

Impacts on Existing and Foreseeable Land Uses

As remarked earlier, aside from mineral exploration and mining, the multiple use National Forest system lands concerned by the Proposed Plan of Operations are primarily managed for cattle grazing, timber and commercial fuelwood harvesting, and wildlife management, and the direct public uses of hunting, firewood gathering, and Christmas tree cutting. The temporary, ephemeral operations covered by the Proposed Plan of Operations would, like the No Action Alternative, have no effect on cattle grazing, timber and commercial fuelwood harvesting, firewood gathering, and Christmas tree cutting. Daylight drill operations during the fall hunting seasons, particularly local noise and traffic, would cause large game to avoid proximity to operations and therefore cause spatially- and temporally-limited interference with public hunting activity. Because only one drill rig would be operating at a time on the widely separated, six exploration projects of the Kaibab JV, impact on hunting would be very local. The No Action Alternative would have no effect on hunting activity on the Tusayan Ranger District Again as commented earlier, recreational use of the Tusayan Ranger District is largely related to public visitation to the Grand Canyon National Park, particularly by way of the use of State Highway 64, overnight camping at the USFS-operated Ten-X campground, and limited special use permits for jeep, ATV, and horse tours in the Tusayan area. All operations under the Proposed Plan of Operations are ten or more miles south of the Grand Canyon National Park, the Ten-X campground, and the Tusayan area special use permit tourist operations involving jeep, ATV, and horse tours. For this reason, the operations of the Proposed Plan would have no effect on the primary recreational use of the Tusayan Ranger District. The same is true of the No Action Alternative. Planned drilling operations on the Sze Prospect, however, would be about 100 yards or meters west of highway 64, and would potentially be visible to particularly attentive tourists and other passers-by traveling the highway. However, it is expected that the tall ponderosa pines covering the Sze prospect would shield operations from notice from


most travelers. See Figure 22 from the Garfield Prospect. The Garfield and the Sze Prospects are very similarly vegetated, with the Sze tree cover being considerable more dense than that at Garfield.

Figure 22. Drill rig at Garfield prospect, dwarfed and camouflaged by ponderosa pines.

Highway 64 is about the same distance from the Sze drilling area as the camera position, and Sze has much more ponderosa pine tree cover along and crossing the line of sight from highway 64.


Impacts on Geology, Pedology, and Hydrology

Effects on Soils and Watershed

Introduction Relevant direction from the Kaibab National Forest Land Management Plan (1988, as amended) and Forest-wide Standards includes consideration of these goals:

• Maintain soil productivity and watershed (i.e. soil) condition. Rehabilitate non-productive lands on a planned basis to eliminate unsatisfactory watershed condition by 2020. Maintain a high quality sustained water yield for Forest users and others. Identify and protect wetlands and floodplains.

• Prevent any new noxious or invasive weed species from becoming established, contain or control the spread of known weed species, and eradicate species that are the most invasive and pose the greatest threat to biological diversity and watershed condition.

• Incorporate measures to maintain soil productivity and watershed condition into project planning, implementation, and monitoring.

Ecosystem Management Area (EMA) Standards and Guidelines add these objectives:

• Formulate and portray, describe, or quantify management objectives and desired conditions for the landscape. In landscapes that involve habitat for threatened, endangered, or sensitive plant or animal species, formulate management objectives and desired conditions for each designated management territory.

• Formulate, design, and implement resource operations or improvements that contribute to the achievement or maintenance of these management objectives and desired conditions.

• Apply best management practices to mitigate adverse effects of activities and maintain site soil productivity.

Other applicable regulatory or legal requirements:

• Clean Water Act, Sections 303, 319, 404 Section 303(d) directs states to list water quality impaired water bodies and develop total daily maximum loads to control the non-point source pollutant causing loss of beneficial uses. The designated uses for ephemeral surface waters in the State of Arizona are aquatic, wildlife, and partial body contact.

• Section 319 directs states to develop programs to control non-point source pollution, and includes federal funding of assessment, planning, and


implementation phases. (At this time, no known Section 319 projects would be detrimentally affected by project activities.)

• Executive Order 11988 – Flood Plain Management: Direction to avoid to the extent possible the long and short term adverse impacts associated with the occupancy and modification of floodplains and to avoid direct or indirect support of floodplain development wherever there is a practicable alternative.

• Executive Order 11990 – Protection of Wetlands: Direction to avoid to the extent possible the long and short term adverse impacts associated with the destruction or modification of wetlands and to avoid direct or indirect support of new construction in wetlands wherever there is a practicable alternative.

• State of Arizona Water Quality Criteria and Designated Beneficial Uses for Water

The overall desired condition is maintenance of sustainable ecosystems within and surrounding the DIR Project Area, in which project activities do not impair important ecosystem functions, such as maintaining soil stability and productivity, watershed health, and water quality. Specific desired conditions that apply to the project include the following:

• Soil erosion and sedimentation of downstream water bodies and ephemeral stream channels will be minimal as a result of project activities.

• Provide for long-term vegetative ground cover and maintain soil productivity and watershed quality.

Direct and indirect effects Off road travel and drilling activities would be short-term and temporary with limited ground disturbance or soil compaction. These activities would only have a minimal effect on the soils and watershed during implementation of the project. Approval of the Proposed Plan of Operations would primarily result in two different categories of soil disturbance: (1) Compaction of soils during project-related vehicle use, and (2) temporary displacement of topsoils during drill cuttings reclamation. During drilling work, soil compaction would take place along the cross-county access routes to the drill sites at the Two-Squares and the Grandpa Prospects. At all prospects, vehicles and/or heavy equipment would be used for short distances off-road to access particular drill hole sites. Use of vehicles off road can damage plants, cause ruts, and cause compaction. However, under the Proposed Plan of Operations, vehicle and equipment used would not be moved when soils are saturated and vulnerable to rutting and erosion. This practice would help avoid most damage to soils. Once drilling operations have been completed, holes would be plugged and pits used for fluid containment (if present) would be filled with stockpiled soils once the fluid in the


pit has dried. Drying time is dependent on weather conditions, but is estimated to be 1 to 4 weeks after drilling operations cease. After completion of exploration operations, the soils compressed by repeated vehicle passage over the cross-country routes into these two prospects would be ripped to a depth not to exceed six (6) inches in order to reverse soil compaction. Limiting ripping depth to six inches would minimize the introduction of deep pedogenic salts to the surface, salts that might otherwise reduce successful revegetation of the soil surface after completion of operations. After reclamation phase ripping of cross-country access routes at Two-Squares and Grandpa, each of these access routes would be blocked and obscured with natural materials at its entrance in order to reduce or prevent further use of the routes by later National Forest users. In addition to this physical access blocking, each entrance area would be marked with a sign advising other National Forest users that the former road area behind each sign is permanently closed for revegetation purposes. The second category of soil disturbance that would result from approval of the Proposed Plan of Operations derives from onsite disposal of drill cuttings brought to the surface during the drilling of each exploration drill hole on all six of the exploration prospects covered by the Proposed Plan of Operations. Drill cuttings from rotary or percussion rock drilling have the texture and the low fertility of sand and gravel. Therefore, in order to make certain that the surface area disturbed by drilling work by being covered with cuttings is successfully revegetated, these cuttings would be buried in shallow pits covered by much more fertile stockpiled topsoil. See Figures 23-24. The low berms resulting from such work would be well-drained due to the deep presence of cuttings, an arrangement that would provide further desalination/acidification of topsoils covering the cuttings (Russell 1973, pp. 764-769). Final site reclamation would consist of raking the drill sites by hand or machine to return the site surface to approximate original contours and reseeding or replanting with native vegetation to restore the integrity of the site. The following summarizes the best management practices (mitigation measures) related to soils and watershed that would be adopted under the Proposed Plan of Operations:

1. Project sites would be kept clean at all times. Engine and equipment fluids and drill fluids would be contained at all times and collected in original or similar containers during maintenance, and would be disposed of at approved off-site disposal facilities. Solid waste (e.g., trash, consumables containers) would be collected and disposed of at approved off-site disposal facilities. No items are to be disposed of on-site.

2. Vehicles would stay on designated driving routes to avoid excessive soil or

vegetation disturbance.


3. To aid in reclamation and to prevent potential negative impacts at certain sites, water and/or drilling fluid that circulates from boreholes would be confined as much as practicable to fluid pits (to be later backfilled), and/or confined within portable tanks.

4. In the event that fuel or equipment fluids are spilled, the affected soil would be

removed for disposal off-site and the USFS would be notified.

5. Heavy equipment and vehicles would not be used off road in the project area when soils are saturated and the potential for road damage and erosion is high. Equipment already on-site would continue to work, but would not be moved until soils are drained and dried sufficiently to avoid wet-soil compaction and rutting.

6. Topsoil would be stockpiled away from cuttings and parent soil material for later

use during reclamation activities. 7. The affected areas would be raked after completion of operations. Mycorrhizae

and native seed would be conserved by spreading a layer of topsoil saved during site preparation and stockpiled. These measures would help to promote native plant establishment and prevent soil erosion and colonization by noxious weeds.

8. Operator established cross-country access routes to and from the sites would be

reclaimed upon project completion, including any amendments, extensions or replacements.

9. Oil and other petroleum products used in the operations would be stored in

approved containers away from drilling areas during operations to prevent environmental contamination.

10. Sites would be revegetated using a seed mix approved by KNF.

Speaking of the expected direct and indirect effects of the Proposed Plan of Operations on soils and watershed, the judgment of W. Liebfried Environmental Services (2009a) is:

Impacts from drilling the exploratory holes would be temporary and would include cross-country travel; disturbance created by the drill holes, such as removal of vegetation and soil; and digging fluid pits, if needed. Moving of heavy equipment would be suspended during weather conditions that result in saturated soils. No long-term adverse environmental impacts are anticipated. Once exploration work is completed at each site, drill holes and fluid pits (if present) would be reclaimed and seeded to restore watershed integrity. Implementation of the Proposed Action may lead to a

small, temporary increase in bare ground and potential minimal soil

erosion in the short term.


No action alternative

Under the No Action Alternative, no additional exploration drill holes -- and no drilling-related disturbance of the soils and watershed at each prospect -- would be completed on the six (6) Kaibab Joint Venture prospects covered by the Proposed Plan of Operations.

Geological and Subsurface Hydrological Impacts

In the event that the Proposed Plan of Operations is approved, the effects on the geology of the project areas would consist of drilling of vertical air rotary/percussion test holes with maximum depths great enough to reach the upper Supai Group sandstones; i.e., about fifteen hundred (1500) feet. The whole of each exploration boring would be well above the Redwall-Muav aquifer. Refer to Figure 2 again for an illustration of this drilling range. Each such drill hole would have an approximate diameter of up to seven (7) inches. Upon completion of the drilling of each exploration drill hole the hole would be plugged with cement after drill hole completion. Cement caps of the drill holes would extend at least two feet into bedrock. If ground water contained in a perched aquifer above the deep Redwall-Muav aquifer is encountered during any of the drilling work, the drill hole intersection of the affected aquifer would be sealed with a completion mud upon drill hole completion in order to prevent surface contamination of the perched aquifer. The Operator would note depth and initial flow rate of the aquifer in any such cases, and this information would be sent to the Tusayan District Ranger and the office of the Arizona State Hydrologist before the end of each calendar year of operations.

Under the No Action Alternative, no additional exploration drill holes -- and no drilling-related disturbance of the rocks at each prospect -- would be completed on the six (6) Kaibab Joint Venture prospects concerned by the Proposed Plan of Operations.


Figure 23. Exploration drilling at Kaibab JV Hummer Prospect, early 1990s, looking easterly.

Light-colored low pile on left hand side of picture is made up of drill cuttings produced during the drilling of the previous drill hole. These cuttings were buried onsite during reclamation. The next picture shows the same general drill site area after completion of reclamation.

Figure 24. Late 1980s to early 1990s exploration drilling area at the Kaibab JV’s Hummer Prospect, looking northerly in 2007.

Before reclamation, the low light-colored cuttings pile on the left hand side of the previous Figure was located just to the right and north of the log shown on the left hand side of this picture.


Worst Case Impacts on Hydrogeochemistry

The hydrological impact of the Proposed Plan of Operations, as far as possible perched aquifers above the deep Redwall-Muav aquifer are concerned, has already been disclosed in the “Geology” effects section above. Not discussed in that section is the hydrogeochemical effect of the injection of water-based drilling fluids into exploration drill holes. Of particular concern is the question of how much uranium (and associated gross-alpha radioactivity) might be added to the water of the Redwall-Muav aquifer below each mineralized breccia pipe as a result of exploration drilling. Another concern is how much impact this exploration drilling would eventually have on Colorado River water chemistry. Recall that previous breccia pipe exploration drilling experience shows that a maximum of 5000 gallons of water can be required to complete each surface drill hole down to and through the level of rock known to contain uranium mineralization in Arizona breccia pipes. The horizontal diameter of mineralized collapse breccia pipes varies from 150 feet to 300 feet (Wenrich 1992). In cases where mineralization is discovered through exploration drilling, the maximum density of surface drill holes placed through such a pipe is 1 drill hole every 50 feet east-west and north-south. At this spacing at the surface, Figure 25 shows that a maximum of 56 surface drill holes would be required to determine the economic feasibility of developing a mine on a uranium-mineralized breccia pipe with a horizontal diameter of 300 feet. Drilling each of the 56 drill holes with a maximum of 5000 gallons of water per drill hole, and assuming all of this water reaches a maximum, worst case concentration of 25 ppm (25 mg/L) uranium (pp. 57-59, this report) by the time it exits the pipe area and continues to descend to the Redwall-Muav aquifer, indicates the following maximum (worst case) uranium contamination of the aquifer by such a drilling program on any given economically uranium-mineralized breccia pipe: 25 mg U/L = X mg U/(56 drill holes x 5000 gallons water/drill hole x 3.785 L/gallon) = X mg U/(1,059,912 L) X mg U = 1,059,912 L x 25 mg U/L = 26,500,000 mg U = 26.5 kg U, or 58.4 pounds uranium/breccia pipe exploration program exploring an economically-mineralized breccia pipe.49

Worst Case Colorado River Water Impacts

Redwall-Muav aquifer ground water affected by the Proposed Plan of Operations comes to surface and drains to the Colorado River through the Havasu Creek drainage. Aquifer waters entering the Colorado River from that drainage and sourced from the proposed Plan of Operations projects area apparently have a maximum average residence time of

49 In cases where no economic grade uranium mineralization is found during exploration drilling, far fewer than 56 or so drill holes are completed on any given breccia pipe prospect.


about 15,000 years, and take anywhere from 4,000 to 10,000 years to reach the River. See Figure 26. The maximum (worst case) increase in Colorado River water uranium concentration that could occur in about 4,000 to 10,000 years from the completion of a one-year 56-hole drilling exploration program on a single economically-mineralized breccia pipe can be estimated as follows. Givens: Current average uranium concentration of Colorado River water = 4.60 ppb U Current average annual flow of Colorado River below Havasu Creek = 11.7x 109 cubic meters/year = 11.7 x 1012 L/year Annual dissolved uranium load = (4.6 g x 11.7 x 1012 L)/(1 x 106 L) = 5.38 x 107 g U/year, or 53,800 kg U, or 59.3 tons U Adding in the maximum (worst case) of 58.4 additional pounds (26.5 kg) of dissolved uranium derived from the maximum water injection associated with the 56 exploration drill holes used to delineate the ore reserves in a 300 foot diameter economically-mineralized breccia pipe has the following worst case effect on Colorado River water uranium concentration: (53,800 kg/year U normal river load + 26.5 kg/year U from a single, 56-hole exploration drill program)/(11.7 x 1012 L/year x 1 kg/ L H2O) = 4.601 ppb U. This very slightly increased (+0.02%) level of uranium concentration under worst case conditions would also, result in no significant or critical increase in the gross-alpha radioactivity of Colorado River water. In the case of the exploration of a single economically-mineralized breccia pipe, then, the worst case impact of the exploration drilling is practically equivalent to the no significant impact case of the No Action Alternative. The same worst case calculation method can be used to estimate just how many simultaneous exploration drilling programs in the same Proposed Plan of Operations area would be required to raise Colorado River water uranium concentration up to the 30 ppb uranium level -- some thousands of years later -- that is believed to mark the threshold between harmful and harmless levels of both uranium and gross-alpha radioactivity: (53,800 kg/year U normal river load + X kg/year from multiple 56-hole exploration drill programs)/(11.7 x 1012 L/year x 1 kg/ L H2O) = 30 x10-9 U. Solving for X; X = 297,000 kg U. Dividing 297,000 kg U by 26.5 kg U/economically-mineralized breccia pipe drill program, shows that some 11,200 drill programs on 11,200 economically-mineralized breccia pipes in a single year (or 627,000 drill holes) would be required to raise Colorado River water uranium concentrations up to 30 ppb in some thousands of years in the future.


Figure 25. Surface drill hole pattern typically used to explore an economically-mineralized breccia pipe.


Figure 26. Average residence time of Redwall-Muav aquifer ground water on Coconino Plateau.


This number of breccia pipe ore discoveries far exceeds the number of breccia pipe ore bodies technically expected to exist in both the South Rim and Arizona Strip portions of the Arizona breccia pipe province (Finch et al., 1990), and far exceeds the annual historical breccia pipe ore body discovery rate shown in Table XXXII of this report. For these reasons, under worst case conditions there is no likelihood that exploration drilling of collapse breccia pipes north or south of the Grand Canyon will raise Colorado River water uranium and radioactivity levels to the EPA thresholds of health concern. Additionally, consideration of the page 56 estimation of likely (expected) case dissolved uranium concentration value of 180 ppb for waters passing through the Orphan Mine breccia pipe even further reduces this assessment of the likelihood of adverse impact on Colorado River water chemistry. One hundred eighty parts per billion uranium is 0.0072 of the 25 ppm dissolved value employed in the worst-case calculations of this report with regard to possible ground water contamination from breccia pipes, their exploration, and their mining development.

Worst Case Havasu Creek Water Chemistry Impacts

The just employed mode of estimation can also be used to gauge magnitude of worst case effect on Havasu Creek waters in some 4,000 to 10,000 years50 after completion of a single 56-drill hole exploration program on a 300 foot diameter economically-mineralized breccia pipe. Givens: Current average uranium concentration of Havasu Creek water = 3.75 ppb U Current average annual flow of Havasu Creek = 6.29 x 107 cubic meters/year = 6.29 x 1010 L/year Annual dissolved uranium load = (3.75 g x 6.29 x 1010 L)/(1 x 106 L) = 236,000 g U, or 236 kg U, or 520 pounds U. Adding in the worst case maximum of 58.4 additional pounds (26.5 kg) of dissolved uranium derived from the maximum water injection associated with the 56 exploration drill holes used to delineate the ore reserves in a 300 foot diameter economically-mineralized breccia pipe has the following effect on Havasu Creek water uranium concentration: (236 kg/year U normal creek load + 26.5 kg/year U from a single, 56-hole exploration drill program)/(6.29 x 1010 L/year x 1 kg/ L H2O) = 4.17 ppb U. This means that, assuming maximal, worst-case pipe leachate uranium concentrations of 25 ppm, there would be a measurable change in Havasu Creek water uranium concentrations due to the drilling exploration of a typical economically-mineralized collapse breccia pipe in some thousands of years. As previously shown, however, this worst-case moderately-increased level of uranium concentration would result in no meaningful increase in the gross-alpha radioactivity of Havasu Creek water.

50 See Figure 26 above and later Figure 35 of this report.


The same calculation method can be used to estimate just how many simultaneous (in one year) exploration drilling programs in the same Proposed Plan of Operations area would be required to raise Havasu Creek water uranium concentration up to the 30 ppb uranium level -- some thousands of years later -- that is believed to mark the threshold between harmful and harmless levels of both uranium and gross-alpha radioactivity: (236 kg/year U normal river load + X kg/year from multiple 56-hole exploration drill programs)/(6.28 x 1010 L/year x 1 kg/ L H2O) = 30 x 10-9 U. Solving for X; X = 1,650 kg U. Dividing 1,650 kg U by 26.5 kg U/economically-mineralized breccia pipe drill program, yields about 62 drill programs on 62 economically-mineralized breccia pipes – i.e., completion of about 3,500 drill holes per year on 62 or so economically-mineralized, 300 foot diameter, collapse breccia pipes could have a material adverse effect on the drinking water quality of Havasu Creek in some thousands of years in the future. Statistical and visual inspection of the historical data of Table 32 of this report, however, shows that the likelihood that 62 separate economic breccia pipe ore bodies will be discovered and drilled to completion in any given year on the south side of the Grand Canyon is nil. Additionally, consideration of the page 56 estimation of likely (expected) case dissolved uranium concentration value of 180 ppb for waters passing through the Orphan Mine breccia pipe reduces this assessment of the likelihood of adverse impact on Havasu Creek water chemistry. 51 One hundred eighty parts per billion uranium is 0.0072 of the 25 ppm dissolved uranium value employed in the worst-case calculations of this report with regard to possible ground water contamination from breccia pipes, their exploration, and their mining development. Under the No Action Alternative, and all other things remaining equal, no change in Havasu Creek dissolved uranium and radioactivity content would likely occur in the future.

51 During the course of the research carried out in completion of this Environmental Assessment, it was learned that experimentation is being conducted in the use of plant-derived humic acids as sorptive and physical barriers to dispersion of heavy metals (and organic compounds) in ground water. See Chapter 10 of the NATO Science Series volume found at: http://www.google.com/books?id=ke0ROik8kXgC&pg=PP1&dq=Use+of+Humic+Substances+to+Remediate+Polluted+Environments:+From+Theory+to+Practice#PPA203,M1, as well as: http://www-ist.cea.fr/publicea/exl-doc/200600000463.pdf and http://www-ist.cea.fr/publicea/exl-doc/200600000465.pdf for more detail. January 2009 contact with Humintech GmbH (http://www.humintech.com) shows that they currently support research in this area and would likely be interested in testing the use of their product for application in the Arizona breccia pipe exploration region. Humic acids are already used in water-based drilling fluids as fluid retention agents and have the pronounced tendency to sequester metals like uranium, reduce hydraulic conductivity in acid environments, and reduce the migration rates of inorganic and organic contaminant plumes. Given these indications that using humic acids in drilling fluids could help minimize potential uranium remobilization into ground water caused by exploration drilling, a useful academic or governmental research project might be to ‘bench test’ this drilling fluid additive under conditions similar to those present in the subsurface of the Northern Arizona breccia pipe exploration region.


Effects on Air Quality, Radiation, and Noise Levels

Impacts on Air Quality

Effects on air quality of the Proposed Plan of Operations would consist of temporary and local increases in suspended dust from drill equipment operations, job-related vehicular travel, and small-scale emissions of diesel exhaust related to operation of drill equipment. None of these effects on the air quality of the Tusayan Ranger District are expected to materially change the baseline air quality described in Table XI above. The type of drilling equipment used includes a cyclone-type dust collector that sequesters most of the rock dust exiting the drill hole once the drill bit has penetrated more than about ten feet below the surface. For this reason, drill operators and helpers are generally subjected to very little rock dust during the course of their daily work. In any case, the particulates generated by the type of drill that would be used are relatively coarse, therefore remain suspended for very limited amounts of time, and therefore travel no farther than, depending on wind velocity, 100 to 200 feet beyond each drill hole collar. See Figures 6 and 27 for photographs of the range of drilling dust released while using air rather than water as a circulation fluid. Figure 27 illustrates dust release while the cyclone dust collector is in operation, and Figure 6 shows the amount of dust that is generated before the drill hole is deep enough to cover the percussion drill bit. Because voids and small caverns created by brecciation and leaching of rocks by acids generated by oxidizing sulfides are usually associated with mineralized breccia pipes, circulation of cuttings to the surface by compressed air and/or drilling fluid is nearly always lost by the time that the Coconino Sandstone is reached by the exploration drill. This geological attribute of mineralized breccia pipes, combined with the use of water-based injection fluids in coring uranium-mineralized intervals, would serve to prevent the generation of dust containing heavy metals while drilling through uranium-mineralized intervals of rock. In addition to dust generated by drilling itself, job-related vehicular traffic during dry weather would raise road dust. Typically, 2 to 3 pick up trucks would enter a given project site at the beginning of the workday, and then exit the site at the end of the day. In the cases where completion of an exploration drill hole requires the use of water, the drilling water truck would make 1 to 2 supply trips each day. This daily road passage activity is similar in scale to that taken by members of a typical two-truck, multiple ATV deer or hunter’s camp, and far less than that of the aggregate tourism-related, permitted ATV and jeep tours taking place in the more northern parts of the Tusayan Ranger District. Previous Figure 23 illustrates the maximum extent of diesel engine exhaust emitted by the drilling equipment that would be used under an Approved Plan of Operations. This sort of diesel exhaust plume is only generated as the hoist on the drill is used to raise and pull out – ten or twenty feet at a time -- the drill string. It takes 1-2 minutes to hoist up each 2-piece 20 foot drill rod segment when pulling up the string to empty a full core barrel, and about double that time while breaking 20 foot sections of rod down into two 10 foot lengths at the end of a hole. This means that with a 1500 foot deep drill hole, it


would take approximately an hour and half to pull out of the hole 20 feet at a time, an hour and a half during which the diesel exhaust shown in Figure 23 would be emitted by the drill rig. Under the No Action Alternative, air quality of the Tusayan Ranger District would only be affected by ordinary migrating smog, controlled and uncontrolled burns, seasonal inversions, residential wood-burning, and tourist and hunter traffic emissions and road dust.

Impacts on Background Radiation and Radon Gas Levels

The Canyon Mine EIS (USFS 1986, pp. 4.6-4.7) reports that workers within that mine can expect to receive direct radiation on the order of 0.8 mrem/hour. According to that study, a Canyon Mine miner can remain “…at or near the high grade ore body during an entire work period and not exceed the weekly guidelines (100 mrem) or the annual whole

Figure 27. Dust emitted by drill rig before drill bit is covered by rock (the bit is still at the top of new hole).

body limit (5,000 mrem).”52 All operations that would be conducted if the Proposed Plan of Operations is approved will be at the surface and approximately 1500 feet above any uranium ore potentially present below the work operations. For this reason, direct radiation received by surface workers during the conduct of the Proposed Plan of Operations from potential uranium mineralization below each project area would be nil, as would be the case under the No Action Alternative. It has already been observed that in cases of uranium drilling exploration on bona fide

52 Therefore, high grade uranium ore of the quality present in breccia pipes is not considered a “hazardous substance”.


mineralized breccia pipes in the Tusayan Ranger District region, drill cuttings circulation to the surface using air or water-based circulation fluids is usually lost by the time a drill has reached down to the Coconino Sandstone; i.e., at depths of about 700 feet. For this reason, the probability that drill bit cuttings generated from drilling through intervals of naturally radioactive, uranium ore located below the Coconino Sandstone at the Hermit Formation to Upper Supai Formation stratigraphic levels, is small.53 However, in the unlikely event that radioactive cuttings are returned to the surface by air or water injected into the drill stem, under the Proposed Plan of Operations, this non-hazardous radioactive material would be buried onsite during reclamation at a depth of three or more feet in order to keep surface radiation levels at their pre-operations levels. Naturally, there is no likelihood that radioactive material will be brought to the surface under the No Action Alternative. Under the Proposed Plan of Operations, the small amounts of radon gas accumulated in the pore spaces of the rock broken up by the exploration drill bit would be carried rapidly to the surface through the open drill hole by the compressed air pushed through the drill rod. Released at the drill hole collar at the top of the hole, this radon would be diluted rapidly and dispersed into the open atmosphere by surface air movement and the impetus of the compressed air operating and clearing the exploration drill bit. Even if a given drill hole penetrates high concentrations of uranium like those expected in an economic ore body, because of the short 2-4 day drill hole completion time, amounts of radon released by such drilling work will be at far lower levels than expected to be present in the mine and released by the vent air for the Canyon Mine (USFS 1986, pp. 4.6-4.7) which will operate for up to ten years, and according to the Canyon Mine EIS (ibid.), mine workers there will be exposed to safe radon and radon progeny levels. Therefore, neither the public or the exploration workers involved in the currently Proposed Plan of Operations would be exposed levels of radon and radon progeny that threaten health. As far as health risk is concerned, this is the same state as exists under the No Action Alternative.

Impacts on Noise Levels

In the event that the Proposed Plan of Operations is approved, the most continuous (one 10-12 hour drill shift/day) sound disturbance would consist of the mechanical and air noises associated with drill operation. A NIOSH illustration of the typical noise levels found immediately surrounding a drill rig of the sort used in breccia pipe uranium exploration is provided in Figure 28 below. Maximum noise level sourced by such an operation is 98-105 dBA immediately adjacent to the drill rig air compressor. Using annual average relative humidity (52.5%), 53 In mineralized pipes, ore is sampled through drill holes by two means. Before enough drilling has been completed to roughly determine the approximate location of the ore contained in the subsurface in a breccia pipe, the presence of ore is only determined by ‘logging’ the drill holes by lowering a probe measuring the levels of natural gamma radiation emitted by the rocks making up the wall of the drill hole. Once the location of the ore body has been ‘roughed out’ with relatively widely-spaced drill holes, the ore-bearing depths of intervening drill holes are sampled by both core drilling and gamma logging. Retrieval of rock cores pushed up into the core barrel at the bottom of the drill rod string provides a direct, tangible sample of the ore material in the breccia pipe. These core samples are invaluable for calibrating the gamma probe equipment, for performing early milling tests, and for planning the eventual mine construction.


temperature (7.67 degrees C), and air pressure (788 millibars) for the very similar Flagstaff environment,54 a band center frequency of 4000 Hz, and the noise attenuation calculator found at http://www.csgnetwork.com/atmossndabsorbcalc.html, indicates that noise from exploration drilling will attenuate, on the average, down to the ambient rural level of 45 dBA no farther than ½ mile of the drill rig.55 At approximately 250 feet away from the drill, noise levels would be dampened to below 85 dBA by the atmosphere. Eighty-five dBA is the threshold necessitating continuous hearing protection for an eight-hour work day exposure. Under the No Action Alternative, noise levels in the project areas covered by this Proposed Plan of Operations would remain as described on page 66 of this report.

Figure 28. Noise intensities around a typical water well drilling rig.

54http://www.wrcc.dri.edu/cgi-bin/clilcd.pl?az03103 55 This calculation disregards added sound attenuation by vegetation and intervening topography.


Impacts on Biological Resources

Plant Impacts

Specific vegetation-relevant direction from the Kaibab National Forest Land Management Plan (1988, as amended) includes these goals:

• Improve habitats for listed threatened, endangered, or sensitive species of plants and animals and other species as they become threatened or endangered. Work toward recovery and de-listing of species.

• Identify and protect areas that contain threatened, endangered, and sensitive species of plants and animals. Consult with the U.S. Fish and Wildlife Service when activities have the potential to impact protected species.

Forest Service Manual 2670:

• Develop and implement management practices to ensure that (sensitive) species do not become threatened or endangered because of Forest Service actions.

Forest Service Manual 2620.1 (1991):

• Manage habitats for all existing native and desired non-native plants, fish, and wildlife species in order to maintain at least viable populations of such species.

• Habitat must be provided for the number and distribution of reproductive individuals to ensure the continued existence of a species generally throughout its current geographic range.

Rare plants Suitable habitats for Tusayan rabbitbrush, Arizona leatherflower, and Flagstaff

beardtongue, Flagstaff pennyroyal, Mt. Dellenbaugh sandwort may exist in the project

area, but no populations are known or were found within the DIR project areas. Tusayan rabbitbrush is known to occur within five miles of the project area. All five species of rare plants are vulnerable to damage or death from crushing and soil compaction that occurs as a result of frequent trampling and vehicle use off road. Some trampling will occur for a short time during implementation of the project. Because the project activities are limited in duration and area, long-term trampling impacts are not expected. Off road vehicles and equipment use will be limited during access to drill sites only and the immediate area around drill holes. If use of vehicles off road is needed, the specific areas will be surveyed before work begins, if required by KNF. If rare plant populations are found, access routes to the sites will be re-routed.


A. Arizona leatherflower (Clematis hirsutissima var. hirsutissima) Arizona leatherflower is an herbaceous perennial with pinnately compound (7-13 leaflets) leaves. Leaflets are narrowly linear. Erect stems arise from a somewhat woody base to an average height of about 12 inches. Unlike other members of this genus in Arizona, this variety rarely forms vines or trailing stems along the ground. Flowering occurs late April through June, fruiting occurs July to August. The solitary flowers occur at the end of each stem and are thick and purplish. Each flower is one to one and one half inches long. Fruits bear a long plumose tail (AGFD 1997). It is known from the Flagstaff area, around Lower Lake Mary, upper Volunteer Canyon and the Tusayan area as well as the Chuska Mountains and the western United States. In Arizona it usually occurs in moist mountain meadows, prairies or open woods and thickets. It is usually found in limestone soils in ponderosa pine or mixed conifer forests between 6800-9000 feet. Arizona leatherflower was originally listed as a Category 1 species in 1980 by USFWS under the Endangered Species Act. It has since been delisted under the Endangered Species Act. It is included on the USFS Southwest Region (R3) sensitive plant list and is known to occur in the Coconino and Kaibab National Forests. The Arizona Native Plant Law (ANPL) also lists it as a highly safeguarded plant. The ANPL defines this designation as pertaining to all parts of the plant including the seeds and fruit. This designation is given to those plant species whose prospects for survival in Arizona are in jeopardy or which are in danger of extinction. Though suitable habitat exists in the Garfield, Maybe and Sze sites, no individuals of

Arizona leather flower were observed during the surveys conducted on November 15 and

23, 2009, dates outside of this species’ flowering and fruiting period.

B. Flagstaff pennyroyal (Hedeoma diffusa)

Flagstaff pennyroyal is endemic to the vicinity of Flagstaff and rims of Oak Creek and Sycamore canyons. It is an herbaceous perennial that forms dense, circular, prostrate mats from 15-22 cm across. The small (1.3cm), tubular, blue flowers occur in clusters of 1-3 along the wiry stems. Flowering occurs June through September (AGFD 2003).

Flagstaff pennyroyal is included on the USFS Southwest Region (R3) sensitive plant list and is known to occur on the Coconino, Kaibab, and Prescott National Forests. The Arizona Native Plant Law (ANPL) also lists it as a salvage restricted plant. The ANPL defines this designation as pertaining to all parts of the plant except the seeds and fruit. Commercial activity is allowed with permits and tags. Flagstaff pennyroyal is found in ponderosa pine forests with canopy covers ranging from 0-86%. It is found between 4500-7000 feet. Associated species include desert columbine (Aquilegia desetorum), blue grama, Arizona fesuce (Festuca arizonica), gambel oak,


cranesbill (Geranium caespitosum), and alligator juniper (Juniperus deppeana). Within these habitats it grows on dolomitic limestone outcrops or soils derived from dolomitic limestone. Flagstaff pennyroyal can be distinguished from similar species by smell or growth habit. It smells of turpentine versus either no fragrance of Hedeoma nanum or the mint or pine pitch aromas of Hedoema drummondii or Hedeoma oblongifolum, respectively. It is also the only species of Hedeoma with wiry prostrate or nearly prostrate stems. All others have an erect growth form. Though suitable habitat exists for the Flagstaff pennyroyal in the Garfield, Maybe and Sze sites, and some of the species it is often found associated with were observed, no

Flagstaff Pennyroyal were observed during the surveys conducted on November 15 and

23, 2009, dates outside of the species’ flowering period.

C. Flagstaff beardtongue (Penstemon nudiflorus)

Flagstaff beardtongue is known only from northern and central Arizona. It is an herbaceous perennial that reaches 50-00 cm tall. The blue-green leaves are leathery. Basal leaves are lance shaped and taper to form a stem. Leaves that form along the stem are clasping and heart shaped. Its lavender flowers bloom from June to August (Arizona Rare Plant Committee 2002). Flagstaff beardtongue is included on the USFS Southwest Region (R3) sensitive plant list and is known to occur on the Coconino, Kaibab and Prescott National Forests. It is found between 4500-7000 feet on dry slopes in eroded or mountainous terrain in ponderosa pine forests. Substrates include rock outcrops of Kaibab limestone or sandstone as well as coarse, loamy, shallow soils with neutral pH. Associated species include gambel oak, alligator juniper and blue grama grass. It can be distinguished from a similar but more common species, Penstemon virgatus, by its shorter stature, its heart shaped versus linear leaves and its hairy versus smooth staminode. Though suitable habitat exists for the Flagstaff beardtongue in the Garfield, Maybe and

Sze sites, and some of the species it is often found associated with were observed, no

Flagstaff Pennyroyal were observed during surveys. Surveys were conducted on November 15 and 23, 2009, dates outside of the species’ flowering period.

D. Mt. Dellenbaugh sandwort (Arenaria aberrans) Mt. Dellenbaugh sandwort is a low-growing (up to 6 inches) perennial herb that produces several stems from a branched woody caudex. Plants are generally glandular-pubescent. Leaves are generally basal, narrow, stiff and sharp pointed with one or more pairs of leaves along the stems. Leaves range from about 1/4 to 3/4 inch long. The small (about 1/3 inch) flowers are white with purple stamens. Flowering occurs May-July (AGFD 2004). Mt. Dellenbaugh sandwort is included on the USFS Southwest Region (R3) sensitive plant list and is known to occur in north to north central Arizona in Coconino, Mohave and Yavapai Counties on basalt or sandy soils. It is the only member of its genus that has


not been found outside of Arizona. It occurs in meadows and meadow edges within oak and pine forests or in pinyon-juniper woodlands. Though suitable habitat for the Mt. Dellenbaugh sandwort occurs in the Bozo and

Grandpa sites, no individuals of this species were observed during surveys. Surveys were conducted on November 15 and 23, 2009, outside of the species’ flowering period.

E. Tusayan rabbitbrush (Chrysothamnus molestus) Tusayan rabbitbrush is the only member of the genus Chrysothamnus that is endemic to Arizona. It is a low perennial shrub with short (7-15mm long), linear, narrow (about 1 mm wide), sessile leaves. It flowers August – October. The yellow flowers are subtended by bracts, called phyllaries that are usually arranged in four vertical ranks (AGFD 2005). Based on USFS records it is known to occur in the center of Section 30 along and north of FR 308 near the Two Squares site, about 1 mile to the south of the Bozo site, and within 1 mile to the northeast and east of the Grandpa site. Tusayan rabbitbrush was originally listed as a Category 2 species in 1980 by USFWS under the Endangered Species Act. It was elevated to Category 1 in 1990 then re-listed as Category 2 in 1993. In 1996 it was de-listed under the Endangered Species Act. It has no state status. It is included on the USFS Southwest Region (R3) sensitive plant list and is known to occur in the Coconino and Kaibab National Forests. Tusayan rabbitbrush has been found exclusively on calcareous soils. This includes alluvium derived from Kaibab limestone or basalt. It occurs in openings in pinyon-juniper woodland and in shrub-grasslands at elevations between about 5700-6900’. Associated species include, but are not limited to, big sagebrush, four-wing saltbush, blue grama grass, dwarf rabbitbrush, juniper and broom snakeweed. Tusayan rabbitbrush is distinguished from the similar dwarf rabbitbrush by its blunt tipped versus acute tipped phyllaries and by its glandular versus hairy achenes. The coarse pubescence on the leaves gives Tusayan rabbitbrush a sandpapery feel. Though suitable habitat exists for the Tusayan rabbitbrush in all sites except Sze, and some of the species it is often found associated with were observed at all sites, no

Tusasyan rabbitbrush were observed during surveys. Surveys were conducted on November 15 and 23, 2009, just past the end of this species’ flowering period. Summary of effects According to W. Liebfried Environmental Services (2009b):

Implementation of the Proposed Action, with the prescribed best management practices and mitigation measures, May Impact Tusayan rabbitbrush, Arizona leatherflower, Flagstaff beardtongue, Flagstaff pennyroyal, and Mt. Dellenbaugh sandwort Individuals or Habitat, But Will Not Likely Contribute to a Trend

Toward Federal Listing or Loss of Viability to the Population or Species.


For all other Threatened, Endangered, Candidate, and Conservation Agreement plant species found in Coconino Country, implementation of the Proposed Action will have No Effect. For all other Forest Service Sensitive plants species, implementation of the Proposed Action will have No Impact.

Wildlife Impacts

Species listed under the Endangered Species Act The project area covered by the Proposed Plan of Operations is outside of known ranges, or lacks suitable habitat, for each animal species listed under the Endangered Species Act (ESA) and identified for Coconino County, Arizona by the U.S. Fish and Wildlife Service. This includes species classified as Candidate or Proposed and species with conservation agreements. Critical habitat for the Mexican spotted owl (MSO) is located in the steep-walled canyons below the rim of the Grand Canyon and not on lands administered by the Kaibab National Forest. There is no habitat for MSO and none is known to occur in the project vicinity. According to W. Liebfried Environmental Services (2009d), “The project

would have no effect on the MSO population and habitat trends.” Forest Service Sensitive Species

The Forest Service Sensitive Species that may have potential habitat in the Proposed Plan of Operations project area include the Allen’s lappet-brown bat, bald eagle, desert elfin, northern goshawk, Merriam’s shrew and Mogollon vole. According to W. Liebfried Environmental Services (2009d), “Noise associated with drilling would have a slight,

short-term negative effect on some individuals, but will not affect the overall distribution

of any of these species.”

Management Indicator Species The seven Management Indicator Species (MIS) that are associated with habitat found in the projects area of the Proposed Plan of Operations are northern goshawk, wild turkey, hairy woodpecker, juniper titmouse, mule deer, elk and Abert’s squirrel. According to W. Liebfried Environmental Services (2009d), “Impacts from the proposed exploratory

drilling will not adversely affect the seven species because of the minimal disturbance

that will occur within the project area and the wide range that these species inhabit.

Noise associated with drilling would have a slight short-term negative effect on some

individuals, but will not affect the overall distribution of any of these species.”

Migratory Birds Numerous migratory bird species occur in the area of the Proposed Plan of Operations. Most of the bird species considered above in the sections on Species Listed under the


ESA, USFS Sensitive Species, and MIS are classified as migratory bird species. In addition, effects on Arizona Partners in Flight (PIF) Priority Species for Cold Desertscrub (Great Basin Desertscrub), pinyon-juniper woodland, and ponderosa pine habitat were evaluated. There are no designated Important Bird Areas near the project areas. No PIF species for cold desertscrub were detected during field investigations. The proposed actions will not adversely affect migratory bird habitat because minimal disturbance will occur during exploratory drilling. According to W. Liebfried Environmental Services (2009d), “The sage thrasher, sage sparrow and Brewer's

sparrow may encounter short-term impacts related to noise disturbance but will not

experience long-term effects on habitat or populations.”

The only PIF species for pinyon juniper woodland detected during field investigations was the pinyon jay, detected on Two Squares, Garfield and Maybe sites. The proposed actions will not adversely affect migratory bird habitat because minimal disturbance will occur during exploratory drilling. According to W. Liebfried Environmental Services (2009d), “The gray flycatcher, pinyon jay, gray vireo, black-throated gray warbler, and

juniper titmouse may encounter short-term impacts related to noise disturbance but will

not experience long-term effects on habitat or populations.”

No PIF species for ponderosa pine were detected during the biological surveys. According to W. Liebfried Environmental Services (2009d), “The northern goshawk,

olive-sided flycatcher, cordilleran flycatcher and purple martin may encounter short-

term impacts related to noise disturbance but will not experience long-term effects on

habitat or populations.”

Summary of wildlife effects Cumulative effects are those that occur from the impact of the proposed action when combined with other past, present, and reasonably foreseeable future activities. Reasonably foreseeable activities are those currently proposed to occur in the next ten years. See pages 34-35 of this report for a summary of foreseeable future activities in the Tusayan Ranger District. According to W. Liebfried Environmental Services (2009d):

Because of the short duration to complete exploratory drilling and limited impact

area at each of the 6 sites, and the commitment to reclamation once the projects

are complete, the Proposed Plan of Operations will have no cumulative effects

on forest resources and no permanent impacts to wildlife habitat will occur.

Implementation of the proposed action would likely not affect population abundance of any of the species analyzed in this report because of the small spatial scale and low intensity of effects that would result from project implementation. Based on rationale provided above, the biological effects determination would be No Effect for the following animal species listed under the 1973 Endangered Species Act and their respective designated Critical Habitats:


• Kanab ambersnail

• Apache trout

• humpback chub

• little Colorado spinedace

• razorback sucker

• Chiracahua leopard frog

• California brown pelican

• California condor

• Mexican spotted owl

• southwestern willow flycatcher

• yellow-billed cuckoo

• black-footed ferret Based on rationale provided above, the biological effects determination would be No Impact for the following Forest Service Sensitive animal species:

• plateau giant tiger beetle

• Mojave giant tiger beetle

• cow path tiger beetle

• Mojave giant skipper

• desert green hairstreak

• desert elfin

• northern leopard frog

• bald eagle

• American peregrine falcon Potential habitat occurs in the project area for northern goshawk and possibly Mogollon vole, so the effects determination is May Impact Individuals or

Habitat, but Will Not Likely Contribute to a Trend Towards Federal Listing or

Loss of Viability to the Population or Species for:

• northern goshawk

• Mogollon vole

Impacts on Range, Noxious, and Invasive Exotic Weeds

Noxious and invasive exotic weeds Because this and all future projects on the Tusayan Ranger District will be mitigated in order to prevent introduction and spread of noxious weeds, the Proposed Plan of Operations would have limited potential for introduction and spread of noxious and

invasive exotic weeds.


Range resources The Proposed Plan of Operations would have no long-term impacts on forage and grazing. No fences would be altered or opened as a result of drilling operations. Livestock could be temporarily displaced from May to October during drilling operations in areas in which drilling and livestock are present, but the impact would be short-lived and not significant. Livestock would acclimate to the drilling activity. Once drilling is completed, the sites will be reseeded with a seed mix approved by the KNF, so there will be minimal loss of forage for a minimal amount of time. Mitigation measures and best management practices specifically recommended by KNF and W. Liebfried Environmental Services are provided below. Recommended Best Management Practices and mitigation measures specific to the Proposed Plan of Operations

1. Remove mud, dirt, and plant parts from project equipment before moving it into a project area. This practice does not apply to service vehicles traveling frequently in and out of the project area that will remain on a clean roadway.

2. Workers need to inspect, remove, and properly dispose of weed seed and plant parts found on their clothing and equipment after being trained to recognize the priority species in the area. Proper disposal means bagging the seeds and plant parts and incinerating them (or bagging, solarizing the bags, and then taking them to a landfill).

3. Minimize soil disturbance to the extent practicable.

4. Monitor the project area for noxious and invasive exotic weeds for 5 years following completion of the project. Control new infestations as staff time and budget allow.

5. All gates will remain closed while traveling on KNF roads.

6. The proponent will inform KNF range staff of fencing in need of repair.

7. No fence will be removed or modified during project activities.

8. The proponent and its contractors will use caution when working and driving in and around livestock and livestock tanks.

9. The proponent and its contractors will avoid activities that could contaminate livestock tanks. Non-operating vehicles and equipment will not be parked or stored within 500 feet of livestock tanks).

Summary of effects According to W. Liebfried Environmental Services (2009d), “With the implementation of

the specific mitigation measures provided by KNF and W. Liebfried Environmental, the

Proposed Plan of Operations will have no significant negative impacts on range


resources, grazing management, or noxious and invasive exotic weeds.” The rationale for this assessment follows. The drill site activities under the Proposed Plan of Operations would create a small amount of bare ground in the short term. This slight temporary loss of forage for grazing would be insignificant given the total area of range on the KNF. This disturbance, combined with equipment brought on-site, would have the potential for the introduction and establishment of noxious and invasive exotic weeds. Best management practices (BMP) and mitigation measures would, however, be in place in an attempt to avoid or minimize the spread of exotic weeds into and over the operations area. Implementation of the Proposed Action, with BMPs and mitigation measures in place, would have, according to W. Liebfried Environmental Services (2009c), “minimal potential to impact

range resources and for the introduction of exotic weeds to the area.”

Impacts on Cultural Resources

Paleowest Recommendations

The following remarks and recommendations to the Kaibab National Forest and the proponent of the Proposed Plan of Operations are taken verbatim from Paleowest’s 2009 report:

The purpose of the cultural resource inventory conducted by Paleowest was to assess the effects that uranium drilling explorations and improvement of several access roads will have on historic properties (cultural resources) pursuant to the National Historic Preservation Act. With the area now surveyed and the sites recorded, the next step is to evaluate the sites against the criteria for inclusion in the National Register of Historic Places (NRHP), the standard litmus test for site significance.

The NRHP is a physical list, but it more often acts as a management tool through its eligibility criteria. Archaeological sites and other historic properties that are eligible for the NRHP are treated similarly to properties that are actually listed.

Briefly summarized, in order to be NRHP-eligible, a site must have integrity and meet one or more of the following criteria:

o Criterion A: Association of a property with a historically important event or set of events.

o Criterion B: Association of a property with a historically important person or persons.

o Criterion C: Possession of characteristic, distinctive, unique, or artistically outstanding qualities of a particular type, period, or method of construction.

o Criterion D: Possession of, or possession of the potential to yield, important information on the prehistory or history of a region or culture.


Eligibility for prehistoric archaeological sites, as a particular class of historic properties considered under the NRHP, is most often assessed against Criterion D. The following presents recommendations for exploration activities for each of the six parcels.

Bozo prospect Site 03-07-04-1877 Site 1877 is recommended as eligible for the NRHP under Criterion D, as it represents a good example of a quarry site that could shed light on stone tool manufacturing and reduction technology. PaleoWest recommends that no activities occur within the flagged boundaries of the site. Site 1877 lies to the northeast of the proposed drilling area and away from any proposed access routes into the project area, so avoidance should be not be a problem. If avoidance is not possible, PaleoWest recommends a single-phase archaeological data recovery plan be prepared and carried out, under the review of the Kaibab National Forest. Under these stipulations, PaleoWest recommends clearance of

the Bozo prospect

Garfield prospect

Site 03-07-04-521

Cartledge (1985) noted that due to the small size of site 521 and the scarcity of artifacts, “the information potential of the site(s) has been largely exhausted by pin-pointing their location on aerial photos, filling out an inventory form and taking a collection.” Resultantly, site 521 does not qualify for inclusion on the National Register. PaleoWest agrees with Cartledge’s (1985) original recommendation of the site. In addition, the site will likely be avoided during exploration activities in that it lies well outside the proposed drilling locations, so no further mitigation work is warranted. Site 03-07-04-523 The site is recommended as eligible for the NRHP under Criterion D, as it can provide additional data regarding the Cohohina Pueblo II use of the Coconino Plateau. PaleoWest recommends that no activities occur within the flagged boundaries of the site. Site 523 lies at the northern border of the Garfield prospect, just outside the boundaries of the proposed drilling exploration and away from any proposed access routes into the project area, so avoidance should be not be a problem. If avoidance is not possible, PaleoWest recommends a single-phase archaeological data recovery plan be prepared and carried out, under the review of the Kaibab National Forest.

Site 03-07-04-524 The site is recommended as eligible for the NRHP under Criterion D, as it represents a good example of a quarry site that could shed light on stone tool manufacturing and reduction technology. PaleoWest recommends that no activities occur within the flagged boundaries of the site. Site 1877 lies to the southeast of the proposed drilling area and away from any proposed access routes into the project area, so avoidance should be not be a problem. If avoidance is not possible, PaleoWest recommends a single-phase


archaeological data recovery plan be prepared and carried out, under the review of the Kaibab National Forest.

Site 03-07-04-526

Site 526 was relocated to confirm that it was located outside the current project area boundaries of the Garfield Prospect. The site was difficult to relocate because the previous UTM coordinates were off by nearly 100 meters. The site lies approximately 35 meters east of the project area and therefore will not be impacted by the drilling explorations. Site 03-07-04-527 Site 527 was relocated to confirm that it was located outside the current project area boundaries of the Garfield Prospect. The site was difficult to relocate because the previous UTM coordinates were off by nearly 100 meters. The site lies approximately 40 meters south of the project area and therefore will not be impacted by the drilling explorations.

Site 03-07-04-699

Wigglesworth and Geib (1987) stated that site 699 had the most research potential of any of the sites documented during their survey and therefore, is recommended as eligible for inclusion on the National Register. PaleoWest agrees with this original assessment. This site has potential to provide further knowledge in understanding the Pueblo II Cohonina occupation of the Colorado Plateau. The site lies only 40 meters west of the proposed drilling explorations and could be difficult to avoid. Its boundaries have been marked with pink flagging tape and no activities should occur in this area. If avoidance is not possible, PaleoWest recommends an archaeological data recovery plan be prepared and carried out, under the review of the Kaibab National Forest. Site 03-07-04-1878 Site 1878 is recommended as eligible for the NRHP under Criterion D, as it represents a good example of a quarry site that could shed light on stone tool manufacturing and reduction technology. PaleoWest recommends that no activities occur within the flagged boundaries of the site. Site 1878 is located near the center of the proposed drilling area and just off of Forest Service access, so the site maybe affected by the drilling activities. If avoidance is not possible, PaleoWest recommends a single-phase archaeological data recovery plan be prepared and carried out, under the review of the Kaibab National Forest. Under the stipulations provided for each site, PaleoWest recommends clearance of the

Garfield prospect.


Grandpa prospect Site 03-07-04-700 Site 700 is recommended as eligible for inclusion on the National Register based on the potential information gained on lithic quarrying behavior and stone tool manufacture. As re-mapped by PaleoWest, site 700 encompasses nearly the entire proposed drilling area in the Grandpa prospect. However, both Wigglesworth and Geib (1987:8) and Hammack (1992) mapped the site with the flat area in the center located outside the site. To shed some light on the discrepancy, PaleoWest contacted Phil Geib via email. His response (personal communication 2009) read, in part:

I could easily see drawing the boundary to include the lower area, it’s all a matter of perception and a matter of when one visits the site, since with little veg. more artifacts might be exposed. As I said in the report, “another archaeologist might draw a different boundary.” Given that the setting (non-hachured area) is a slight basin, I can easily envision sediment washing in and covering artifacts, so if one were to excavate a test unit or two there, it seems probable that numerous remains could be found. It might be useful to get some larger context by defining the overall site boundary, since figuring this out might show that the entire Grandpa claim is within a quarry/chert source. The larger issue might be, will the proposed drilling, or what ever they are doing, damage the site in any significant way? I’m not sure what the end result of their drilling activity will look like, but it seems that if done “right” that any impact would be negligible.

Geib’s original recommendation for accessing the drilling areas over parts of the site was that the use of carefully selected and flagged access routes across the site “is recommended as long as a rubber-tired truck is used” (Wigglesworth and Geib 1987). PaleoWest concurs with this recommendation that a qualified archaeologist help select

and flag access routes across parts of the site. PaleoWest also endorses the earlier

recommendation that drilling be allowed in the flatter area that was previously not

included as part of the site, but that PaleoWest has now included. PaleoWest

recommends that because of its low density of artifacts, the area be considered a non-

contributing element to the site’s eligibility. But a qualified archaeologist should help

select drill sites in this area that are least likely to impact any surface artifacts and be

present to monitor initial ground disturbance in the upper meter of soil to ensure that no

buried cultural deposits are present.

It is recommended that the siting of any drilling operations proposed in other parts of the

Grandpa prospect be in low-density areas and preceded by a program of mapping,

collection, and analysis of materials that will be affected.

If avoidance of any Register-contributing elements of the sites is not possible, PaleoWest

recommends that a single-phase archaeological data recovery plan be prepared and

carried out, under the review of the Kaibab National Forest. If subsurface artifacts or

cultural features are discovered during drilling, all ground-disturbing activities should

be immediately halted until further consultation can be conducted. Similarly, if changes


are made to the existing area of potential effect, then additional consultation and field

inventory should be carried out.

Maybe prospect

Site 03-07-04-058

Site 58 represents the only site not relocated during the current survey. Wigglesworth and Geib (1987:8) plot the map within their project area, but make no mention as to whether site 58 was ever relocated. Based on the maps available, the site is currently plotted in the NW ¼ of the SE ¼ of Section 15, which differs from the site inventory sheet that says the site is located in NW ¼ of the SW ¼ of Section 15 Township 29 North Range 3 East. If the site is located as noted on the site records, it falls outside the current project area of the Maybe prospect. Site 03-07-04-589 The site is recommended as eligible for inclusion on the National Register based on the information it could provide regarding the Cohonina use of the Coconino Plateau area during the Pueblo II period. Currently, the site is marked in pink flagging tape and located outside the proposed drilling exploration area and away from any access roads; therefore, avoidance should not be difficult. However, if avoidance is not possible, PaleoWest recommends a single-phase archaeological data recovery plan be prepared and carried out, under the review of the Kaibab National Forest.

Site 03-07-04-696

Site 696 is considered as eligible for inclusion on the National Register based on the information it could provide regarding the early Cohonina and Early Archaic use of the Coconino Plateau. Currently, the site lies on the eastern border of the proposed drilling area, and therefore, could be affected by drilling activities. The site boundaries are marked in pink flagging tape and should be avoided during drilling. However, if avoidance is not possible, PaleoWest recommends a single-phase archaeological data recovery plan be prepared and carried out, under the review of the Kaibab National Forest. Under the stipulations provided for each site, PaleoWest recommends clearance of the

Maybe prospect.

Sze prospect

Site 03-07-04-1151 Site 1151 is recommended as eligible for inclusion on the National Register. Hammack (1992:17) recommended the site as eligible because of the potential information gained regarding subsistence practices, site types, and land use practices. Weintraub (1999) also recommended the site as eligible. PaleoWest agrees with this recommendation and believes the site is avoidable, because although the site lies within the proposed drilling exploration, it lies on the east edge of the area adjacent to the right-of-way of Highway 180/64.


The site boundaries are marked in pink flagging tape and should be avoided during drilling. However, if avoidance is not possible, PaleoWest recommends a single-phase archaeological data recovery plan be prepared and carried out, under the review of the Kaibab National Forest. Site 03-07-04-1874

Site 1874 is recommended as eligible for inclusion on the National Register under Criterion D, as it represents a good example of a habitation site and associated sheet midden that could shed light on the Cohonina use of the Coconino Plateau during the Pueblo II/III periods. The site has potential to provide further information regarding site types and land use practices in the area. The site boundaries are marked in pink flagging tape and must be avoided during drilling. Since the site is located on the east side of Highway 180/64 where no drilling activities are proposed, this entire side of the project area should remain off limits to construction personnel. However, if avoidance is not possible, PaleoWest recommends a single-phase archaeological data recovery plan be prepared and carried out, under the review of the Kaibab National Forest. Site 03-07-04-1875

Site 1875 is recommended as eligible for inclusion on the National Register under Criterion D, as it represents an excellent example of a multi-structure habitation site and associated sheet midden that could shed light on the Cohonina use of the Coconino Plateau during the Pueblo III period. The site has potential to provide further information regarding site types and land use practices in the area. The site boundaries are marked in pink flagging tape and must be avoided during drilling. Since the site is located on the east side of Highway 180/64 where no drilling activities are proposed, this entire side of the project area should remain off limits to construction personnel. However, if avoidance is not possible, PaleoWest recommends a single-phase archaeological data recovery plan be prepared and carried out, under the review of the Kaibab National Forest. Under the stipulations provided for each site, PaleoWest recommends clearance of the

Sze prospect.

Two-Squares prospect

Site 03-07-04-1876

Site 1876 is recommended as eligible for inclusion on the National Register based on the potential information gained on lithic quarrying behavior and stone tool manufacture. Site 1876 encompasses nearly the entire northwest corner of the Two Squares prospect and lies just within the proposed drilling exploration area. The site boundaries do not appear to extend any further east than what is currently defined; therefore, if all drilling exploration occurs either to the south of the access road or in the northeast quadrant of the project area, then avoidance should not be difficult. Because the site does border the access road on the north side, it is recommended that grading and blading activities are


limited to the existing road or occur to the south and east of the road. The site boundaries are marked in pink flagging tape and must be avoided during drilling activities. However, if avoidance is not possible, PaleoWest recommends a single-phase archaeological data recovery plan be prepared and carried out, under the review of the Kaibab National Forest. Under the stipulations provided for each site, PaleoWest

recommends clearance of the Garfield prospect.

Summary

The purpose of this Class III inventory was to assess the effects proposed uranium exploration will have all cultural resources within the project area. Eleven previously recorded sites and five newly discovered sites were documented as part of this inventory. One site (58) was not relocated, but likely lies outside the Garfield prospect, two sites (526 and 527) lie outside the project area and will not be affected by the drilling activities, and one more site (521) is recommended as ineligible for inclusion on the National Register and therefore warrants no additional protection. Sites 524, 696, 699, 1151, 1874, 1875, and 1877 should be easily avoidable, as they lie well outside the proposed drilling areas. However, sites 700, 1876, and 1878 could be directly affected by the drilling operations and difficult to avoid. A recommended

approach to achieving a “no adverse effect” determination is outlined in the earlier

Recommendations section.

Impacts on Socioeconomic Resources and the Socioeconomic Aspects of Environmental Justice

Until such time that mines are established in an area, mineral exploration work like that proposed here generally has relatively limited direct positive impact on the socioeconomic resources of the area where the exploration is conducted. This largely because of the necessarily very large initial “leakage”56 of exploration expenditures to suppliers, contractors, and labor located outside the region until such time that long-run demand for exploration- and mining-related supplies and services becomes strong and consistent enough to help create or expand supporting industries in the exploration and mining area, and local hiring and/or domiciling of technical and other staff.57 Once

56 See www.cefns.nau.edu/Orgs/CPESU/current/documents/nau57finalreport.pdf to read a very pertinent discussion of a somewhat similar industry, Colorado River running. According to this paper, “Regional economic impacts of Grand Canyon river runners”, by Hjerpe and Kim, 2007, “leakage” diminishment of positive economic effects occurs because expenditures of river runner clients are largely funneled to equipment manufacturers outside the region, because many commercial outfitters are located outside of the Grand Canyon area, and because the majority of employee compensation and business expenditures for the commercial outfitters are incurred and paid outside of northern Arizona. Exacerbating this negative trend in the case of Grand Canyon River running is the fact that costs like low wages, temporary employment, and increased demand for services like policing, transportation, fire, and health care are externalized to the local communities without proportionate tax reimbursement by ‘outsiders’. 57 Case in point regarding the uncertainty and risk attending the mineral exploration stage of mining: Three mineral exploration companies supported a Coconino County exploration staff of at least six geologists from 2006 up until late 2008, with a gross annual payroll of more than $400,000. The uncertainty created by the sociopolitical climate in early 2008, especially that marked by Representative Grijalva’s March 2008


mines are established in a region, and ore bodies continue to be discovered and developed consistently, however, businesses supporting both mineral exploration and mining activities would begin to be started in the area (or begin to move into the area) – and mining companies would begin to hire locally, and/or move in the specialized personnel necessary to conduct long term exploration and mining business activities. This mature stage of the mineral exploration and mining industry is the stage that would evidence the strongest socioeconomic benefits to an industrially undiversified region like Coconino County. These potential positive induced socioeconomic effects of early stage mineral exploration work, and later stage mine development and mine operations work, are further discussed in the following cumulative impacts section of this report. Under the No Action Alternative, the Proposed Plan of Operations would not be carried out and the Kaibab Joint Venture would be unable to conduct work necessary to discover and develop breccia pipe ore bodies that would lend support to the establishment of a mature, socioeconomically beneficial mining industry in Coconino County. Regarding the economic aspects of environmental justice: Because local hiring is so limited in the mineral exploration stage, especially when uncertainty of work tenure exists for reasons very largely outside the control of mining companies, little or no positive socioeconomic benefit to minority and/or low wage earning can be expected until such time that the communities of the region effectively accept entry of the industry, and mines are developed in Coconino County. Pending this stage of development of a Coconino County uranium mining industry, the Proposed Plan of Operations would have little or no economic environmental justice impact of any sort on minorities and/or people employed in the low-wage jobs characteristically associated with Coconino County’s well-established tourism industry (Hjerpe and Kim, 2007). Under the No Action Alternative, the Proposed Plan of Operations would not be carried out, and the Kaibab Joint Venture would be unable to conduct work necessary to develop breccia pipe ore bodies potentially present on the six projects covered by the Proposed Plan of Operations, work that would lend support to the establishment of a mature mining industry in Coconino County. As will be shown in the following section, the indirect and induced impact of the Proposed Plan of Operations, and its cumulative like, would be to increase the socioeconomic aspect of environmental justice contained within Coconino County. Under the No Action Alternative, with all other things remaining constant, no change in the level of environmental justice currently present in Coconino County would occur. Potential effects on the natural environment from the Proposed Plan of Operations related to the matter of environmental justice and minorities are considered in the following cumulative impacts section of this report.

Flagstaff public hearing regarding uranium exploration and mining in Northern Arizona, directly influenced each of these companies to transfer and/or lay-off their local staff members.


Cumulative Impacts

Introduction

Council on Environmental Quality NEPA regulations require an analysis of the impacts of a proposed action to determine whether the proposed action, together with related actions, might result in cumulatively significant impacts. Cumulative impacts are those which result from the incremental effects of the proposed action when added to other past, present, and reasonably future action. Work like that which would be conducted under the Proposed Plan of Operations would have direct cumulative effects on the Coconino County region, and indirect cumulative effects that would come to expression in the County and its surrounds in the event that mineral exploration is permitted to continue in an economically practicable fashion, and in the subsequent and related events that one or more additional mines are developed on uranium-mineralized collapse breccia pipes located within the County. These cumulative impacts can be subdivided, for the purposes of this Environmental Assessment, into three categories:

1. Cumulative impacts on racial minorities living within the County. 2. Cumulative impacts on the economically-disadvantaged domiciled in the County. 3. Cumulative impacts on the natural environment and population of Coconino

County as a whole. A meaningful estimate of the material basis for the future cumulative impacts of exploration activity can be obtained by making reference to the historical uranium exploration work that took place in Mohave and Coconino Counties from the late 1970s through late 1980s. BLM and USFS records from that time period measured the amount of surface impact taking place on BLM and USFS ground, and the long-term effects of this surface impact. Corporate records dating from the same period of time show the rates of economically-mineralized breccia pipe discovery and subsequent mine development in northern Arizona, rates that can be expected to continue into the future as long as the economic and social climate remain sufficiently supportive of this sort of industrial activity, and as long as the degree of technical difficulty of discovering these deposits remains constant. As this report will also show, utilization of the BLM, USFS, and corporate records pertaining to historical mining and exploration activities on Federal ground in Mohave and Coconino Counties permits estimation of the rates and effects of future mineral exploration and mining on private and State Trust lands in Coconino County. Annual work quantities carried out by corporations on USFS and BLM lands in Mohave and Coconino County for the purpose of locating and mining economically-mineralized collapse breccia pipes from 1978 through 1988 are listed in Table XXXII. “Exploration acres” in that Table refers to the maximum amount of temporary surface disturbance recorded in historical plans of operations related to breccia pipe exploration drilling, including access routes. “Mine acres” in the same Table refers to the maximum amount


of temporary surface disturbance recorded in historical plans of operation related to breccia pipe mine development and operation, including related access routes. The Appendix describes in detail the econometric least-squares estimations of the linear production functions that describe the 1978-1988 exploration and mining activity in northern Arizona on BLM and USFS lands located in Mohave and Coconino Counties. Lagged annual spot price level of yellowcake produced from uranium ore mined from ore deposits like the Arizona breccia pipes was statistically determined to be a statistically significant predictor of the annual number of exploration drill holes, area of surface disturbance due to exploration drilling, and the number of economically-mineralized breccia pipes discovered each year. Price was an insufficient predictor of new mine start-ups, however.58 Nonetheless, the 1978-1988 BLM and USFS time-series data indicate that an average of 0.73 breccia pipe uranium mines were started up each year during the previous period of breccia pipe uranium exploration and mining on BLM and USFS-administered ground. See Table XXXII again.

Table XXXII. Aggregate Annual Exploration and Mining Work Quantities, US Forest Service and US Bureau of Land Management Lands, Mohave and Coconino

Counties, 1978-1988

Year Exploration Acres

Exploration Drill Holes

Ore Body Discoveries

Mines Started

Mine Acres

1978 2.0 4 0 0 0.0

1979 0.0 0 0 0 0.0

1980 6.5 48 1 0 0.0

1981 41.9 165 0 1 55.4

1982 57.2 269 3 2 87.3

1983 148.4 315 2 0 0.0

1984 237.8 623 1 1 75.3

1985 57.8 101 1 0 0.0

1986 135.5 365 1 1 84.5

1987 75.4 107 1 2 45.7 1988 99.6 124 1 1 19.5

Totals 862 2221 11 8 367.7

Average per Year

78.4 193 1 0.73 33.4

Standard Deviation

73.1 187 0.89 0.78 37.0

95% CI 0 to 303 0 to 746 0.4 to 1.6 0.21 to 1.26 0 to 130

95% CI as qty./square mile/year59

0 to 0.21

0 to 0.51

0.0003 to

0.0011

0.00014 to

0.00086

0 to 0.088

58 Probable factors influencing price’s failure as an independent variable predictor of mine start-up include: 1) regulatory delay and uncertainty in mine plan approval, 2) the fact that only a single company elected to develop mines in northern Arizona during the 1978-1988 period, and 3) greater scale of investment involved in mine construction versus conducting pre-mining mineral exploration. 59 Assuming 1470 square miles of breccia pipe-prospective combined BLM and USFS ground.


Agencies utilizing the cumulative impact models provided in this Environmental Assessment should monitor actual quantities of future work progress achieved by corporations working in the area in order to determine if any structural changes60 have occurred that would affect the validity of the models concerned. If such changes are detected, reassessment of the cumulative impacts of breccia pipe exploration and mining work would be warranted.

Modeling of Future Exploration and Discovery Quantities

Managerial decision-making of uranium mining companies with regard to budgeted

intensity and success of mineral exploration activities is primarily driven by the price

level of this mineral commodity (Price 2005; Müller-Kahle 1990).61 Ordinary least squares regression62 of the annual number of acres of exploration surface disturbance, annual total of exploration holes, and annual total uranium ore body discoveries for the corporate, USFS, and BLM data provided in Table XXXII above against lagged annual average spot price for uranium (yellowcake) yielded the following linear equations:63 Equation 1: Ln (EXA) = 7.0481361 – 2.9318118 x Ln [Price(-2)] + 2.1876778 x Ln [Price(-3)] t = (5.661838) (-2.759298) (2.313396)

prob. = (0.0024) (0.0399) (0.0686)

std. error = (1.244850) (1.062521) (0.945656)

R-squared = 0.637634; Durbin-Watson stat. = 3.090806

Equation 2: Ln (EXH) = 4.8416679 – 2.5857622 x Ln [Price(-2)] + 2.6021975 x Ln [Price(-3)] t = (2.812658) (-1.759908) (1.989966)

prob. = (0.0374) (0.1387) (0.1033)

std. error = (1.721385) (1.469260) (1.307659)


Equation 3: Ln (DISC) = -2.118777 – 1.7873386 x Ln [Price(-4)] + 2.5030242 x Ln [Price(-3)] t = (-4.461235) (-4.592957) (6.142107)

prob. = (0.0111) (0.0111) (0.0036)

std. error = (0.474931) (0.389148) (0.407519)


60 In economics a “structural change” is a strong, basic change in a market, industry, or economy that evokes a material change in the manner or conditions under which an entity operates, and, consequently, evokes a strong, material change in that entity’s behavior and effect in the environment-at-large. For a pertinent example, if mining companies discover or establish a new exploration technique that significantly increases the efficiency and rate of discovery of collapse breccia pipes, then annual surface disturbance of BLM- or USFS-administered lands from exploration drilling could decrease significantly. 61http://www.nea.fr/html/pub/newsletter/2005/23-1-uranium-price.html and http://www.iaea.org/Publications/Magazines/Bulletin/Bull323/32305082933.pdf. 62 Employing version 2.0 of Quantitative Micro Software’s EVIEWS econometric software. 63 “Ln” = natural log; “EXA” = annual exploration acres; “EXH” = annual exploration drill holes; “DISC” = annual ore body discoveries; “PRICE(-2)” = uranium price two years previous; “PRICE(-3)” = uranium price three years previous; “PRICE(-4)” = uranium price four years previous. Note that the coefficients of these constant elasticity equations are also elasticities of these coefficients. Value of the elasticity for each variable measures the percentage change in the dependent variable caused by a one percent change in the controlling variable concerned.


The negative sign of the “Price(-2)” coefficients in the exploration surface disturbance acres equation and the exploration drill hole equation is believed to have arisen due to mining company management’s tendency to reduce exploration budgets when year-to-year price trend is downward. On the other hand, the contrast in signs of “Price(-4)” and “Price(-3)” in the ore body discoveries is interpreted to reflect management tendency to increase uranium exploration budgets on an upward uranium price trend: Increased budgets, all other things being equal, lead to increased discovery rate. The fact that the discovery equation regresses against uranium price points farther back in time than the exploration drill hole and exploration surface disturbance equation estimates, is consistent with the fact that ore body discoveries are relatively rare and difficult accomplishments that take more extended applications of time, budget, and perseverance. Because the 1978-1988 period of USFS and BLM work quantities records sampled a limited portion of the uranium market price cycle, the three econometrically-estimated equations above were used to conduct Monte Carlo simulations64 against random fluctuations in uranium price in order to estimate the full range of temporary exploration surface disturbance, number of drill holes, and number of discoveries that could be expected over time in northern Arizona. This modeling strategy makes it much more

likely that levels of exploration activity possible under all possible uranium price

conditions are fully represented in the planning data presented in this NEPA

Environmental Assessment. Figure 29 shows the historical uranium spot price (2008 constant dollars) distribution sampled in the Monte Carlo simulations that generated the cumulative frequency diagrams of Figure 30, Figure 31, and Figure 32. Note that the last three Figures depict the frequency distribution of each quantity in terms of rate per year per square mile. These rate representations, derived from 1978-1988 BLM and USFS records for USFS lands and BLM lands explored during the time period concerned, are applied in this EA only to the areas illustrated in Figure 33. Historical breccia pipe discovery records (including pre-1978 records) and other geological criteria were used to define the boundaries of these areas. These area-qualifying data strongly indicate all future economically-favorable uranium breccia pipe discoveries will be made within these boundaries. As most of this data is public domain knowledge, it is expected most, if not all, future corporate exploration and mining activity will be focused within the lands identified in Figure 33.65

64 Using version 3.5 of Palisade Software’s @Risk for Microsoft Excel simulation program, with 50,000 iterations in each modeling run. A Monte Carlo simulation mathematically runs through all the possibilities inherent in any given situation and then provides output data that reflect the probabilities of the various possible outcomes. In essence, this modeling tool provides much more precise and more useful best-case, expected-case, and worst-case scenario analysis. Unsurprisingly, the simulations showed that

much more exploration and mining activity can be expected when uranium price level is high. 65 There are other lands in northern Arizona prospective for breccia pipe uranium exploration and mining, but these activities are currently restricted due to regulation or the intent of the owners of the lands concerned.


Figure 29. Log10-log10 cumulative frequency diagram of 1965-2008 U3O8 spot price/pound.

Data from page 29 of Pool 2008.66 According to this graph, the annual average uranium (U3O8) spot price

is over the approximate average total breccia pipe uranium production cost (2008 $) of ~$30/pound about

60% of the time. This means that hesitation in breccia pipe exploration and mining activity can be

expected 40% of the time, all other things being equal. Note that the y-axis on this graph is the log10 value of the 2008 dollar spot price for yellowcake uranium.

Figure 30. Modeled annual total bonded disturbance acreage/square mile of prospective USFS and BLM ground as a function of lagged uranium price.

All other things being equal, increase in uranium price results in increased plan of operations acreage. Largest price influence on annual bonded acreage amount goes back to prices current two and three years before a plan of operations is filed.

66 http://dels.nas.edu/besr/docs/Pool.pdf


Figure 31. Modeled annual total exploration drill holes/square mile of prospective USFS and BLM ground as a function of lagged uranium price.

All other things being equal, increase in uranium price results in increased amount of exploration drilling. Largest price influence on annual hole drilling rate goes back to prices current two and three years before year of drilling.

Figure 32. Modeled annual economically-mineralized breccia pipe discovery rate/square mile of prospective USFS and BLM ground as a function of lagged uranium price.

All other things being equal, increase in uranium price results in increased number of discoveries of economically-mineralized breccia pipes each year. Largest price influence on discovery rate goes back to prices current three and four years before discovery.


Figure 33. Index map showing red-outlined lands currently open to uranium exploration and mining, and which are expected to continue to yield economic discoveries of uranium-mineralized breccia pipes.

Areas B, C, and F are proximal to the lands concerned with the Proposed Plan of Operations.


Given their geological similarity to USFS and BLM lands in Figure 33, future annual exploration and discovery rates on the 680 square mile area of State Trust Lands and private lands immediately southwest of the Tusayan District of the Kaibab National Forest are expected to be equivalent to the per square mile rates modeled for the USFS and BLM lands. On the basis of their late 1970s to late 1980s work experience, both the US Forest Service (USFS 2008, p. 29) and the US Bureau of Land Management (BLM 1992, pp. 3.32-3.58) have both concluded that the surface impact of uranium exploration and mining activity on the lands that their agencies manage is neutral, assuming sufficient operator and agency care and mitigation. Over the long-run, this is similar to the case under the No Action Alternative. This being so, and given that uranium price versus exploration

activity modeling shows that future exploration activity rates (Figures 30 through 32)

will remain in the same magnitude67

as shown historically in Table 32, the remainder

of this Chapter is devoted only to the cumulative impacts of the exploration work

covered by the Proposed Plan of Operations on the subsurface environment, as well

the cumulative impacts of mining on the social, cultural, and environmental justice

aspects of the human environment. Because the quantity and rates of exploration on the surface environment are expected to be in the same range as in the past, and the past rates have already been determined to be neutral with care and mitigation, no cumulative surface impacts on the surface natural environment are expected. Because the scale of employment in uranium exploration is much smaller than in the mining phase, as discussed in pages 127-128 of this report, no cumulative social, cultural, and environmental justice are expected from this phase of uranium mining industry work in Coconino County.

Cumulative Impacts on Racial Minorities

Aside from potential adverse cultural effects of the Proposed Plan of Operations on proximal American Indian tribes that are yet to be discussed during USFS-tribal consultations (page 81, this report), this Draft Environmental Assessment has raised the possibility that the use of water in the drilling of economically-mineralized breccia pipes on particular State Trust and private lands (“F” area) and certain National Forest lands (“C” area) identified on Figures 33 and 35 could adversely affect the drinking water quality of Havasu Creek flowing through the Havasupai Reservation. Estimations already presented (pages 106-107, this report) indicate that, under worst case conditions of maximal uranium mobilization into drilling-introduced ground water, about 62 economically-mineralized breccia pipes would have to be completely drilled out in a single year in order to bring the dissolved uranium levels of Havasu Creek up to the 30 parts per billion range held by the EPA to be unsafe for drinking some 4,000 to 10,000 years in the future. In order to reach this cumulative adverse impact on drinking water quality of Havasu Creek in the Havasupai Reservation, this amount of ore body exploration work would require the:

67 Comparing the last row of Table 32 to Figures 30 through 32 will show that there is approximately a 90% probability that the future annual rates of exploration acreage, exploration drill holes, and ore body discoveries are all within the 95% confidence interval exhibited by the historical 1978-1988 BLM and USFS records.


1) Completion of a minimum of about 3,500 drill holes in one year on the equivalent

of 62 typically-sized, economically-mineralized breccia pipes within the “F” and “C” areas shown on Figure 35;

2) That ground water travel times from beneath each of the drilled breccia pipes to

the springs of the Havasu Creek drainage be equal; and,

3) Uranium taken into solution at economically-mineralized breccia pipes remain permanently in solution over a period of about 4,000 to 10,000 years, and along a horizontal flow path of length of 20 to 70 miles.

Figure 34 shows the basic model of the mechanism behind the potential adverse effect of breccia pipe exploration drilling on Havasu Creek drinking water quality.

Figure 34. Model showing potential long-run effect of ‘wet’ exploration drilling on Redwall-Muav ground water discharging in the Havasu Creek drainage.

Figure 35 shows the distribution of average residence times of Redwall-Muav aquifer ground water within areas C and F as determined by USGS ground water sampling and analysis. The 4,000 to 10,000 year range in travel time of ground water in the Redwall-Muav aquifer from locations in areas C and F to the Havasu Creek springs was determined from the contoured USGS data depicted in this Figure. Figure 36 shows approximate directions of movement of the Redwall-Muav ground water from areas C and F. In area C, Redwall-Muav aquifer ground water moves southwest from the Grandview Monocline area towards the Cataract Canyon/Havasu Creek drainage. In area F, this southwesterly direction of ground water from the Grandview Monocline Redwall-


Muav water table divide continues in the eastern side of area F, but changes to northwesterly along the western side of this area of private and State Trust lands. By comparing Figure 35 and Figure 36, it can be seen that ground water average residence time and flow direction of the water in the Redwall-Muav aquifer are closely related – the oldest water on the Plateau is that which has migrated in towards the NNW-trending elongate lobe of >12000 years residence time The water table divide that largely encircles areas C and F recruits ground water on the northeast, east, and southeast, and then ‘funnels’ this ground water towards the primary Redwall-Muav aquifer natural out-

Figure 35. Detailed map showing average residence time of Redwall-Aquifer ground water in the Coconino Plateau proximal to the Grand Canyon.

let of the Havasu Creek springs. It is suspected that the lobe of high average residence time water south of the Havasupai Reservation is a contouring program artifact caused by insufficient water well data points south of the high residence time lobe and/or caused by ‘back up’ of Redwall-Muav aquifer ground water recharge at that general locale.


It was noted earlier in this report that – assuming pipe-derived uranium stays permanently in solution, and that travel times of migrating mobilized uranium to the Havasu Creek drainage are equal – the addition of 1650 kilograms/year or more of uranium to the Redwall-Muav aquifer by exploration drilling could potentially raise the uranium concentration of Havasu Creek waters up to the 30 ppb EPA MCL. The approximate probability of such an event occurring under the foreseeable range of price-driven uranium exploration activity can be calculated using a numerical model constructed from the hydrogeochemical concepts introduced in pages 52-61, and 103-108, of this report, in conjunction with the linear equation econometrically estimated for the annual number of discoveries/square mile in the northern Arizona uranium-mineralized breccia pipe province (equation #3, page 131, this report).

Figure 36. Detailed map showing elevation of the top of Redwall-Aquifer ground water, and its direction of flow, in the Coconino Plateau proximal to the Grand Canyon.


The numerical model run through Monte Carlo simulation using Palisade Corporation’s add-in for Microsoft Excel, @Risk, in order to estimate probability of adverse effect on Havasu Creek has the general functional form:

Uranium/year added to Redwall-Muav aquifer = f (price, concentration of uranium in descending drill water, area of ground being explored, amount of drill water used).

Note that price determines (R2 = 0.935) the number of discoveries made per year per square mile, and that evidence provided in this report indicates that average concentration of uranium in water descending through a breccia pipe uranium ore body probably has a concentration in the magnitude of 0.180 ppm U (180 ppb U), but may vary up to about 25 ppm U (maximum uranium concentration in a saturated solution of uranium in presence of concentrated sulfuric acid derived from oxidizing metal sulfides). The specific linear function used to model the probability of adverse effect on the Havasu Creek drinking water is a nested and /or serial combination of several specific equations and constants:

1) Ln (Price) = Normal (mean of ln price, standard deviation of ln-price) = Normal (3.56, 0.688). Under the @Risk program, price is randomly determined assuming a normal distribution of price values, starting at annual current spot uranium price. In the Excel/@Risk spreadsheet set-up, each year’s value used the previous year’s average price as the mean.

2) Discoveries per square mile = specific econometrically-estimated equation #3

provided on page 131 of this report divided by the 1470 square mile area of USFS and BLM 1978-1988 exploration lands shown on Figure 33. The ln-values values for number of discoveries generated under simulation under the influence of price change simulation were converted back to antilog values using the natural exponent.

3) Number of drill holes/year completed per discovery = Uniform (minimum,

maximum) = Uniform (1, 60). Under the @Risk program simulation used here, the number of drill holes completed each year was randomly determined using the @Risk Uniform simulation function assuming uniform distribution of annual ore hole completion,68 varying from 1 to 60 per year/ore body.

4) Concentration of uranium in leachate derived from drill water passing over and

through economically-mineralized breccia pipe uranium mineralization = Uniform (minimum, maximum) = Uniform (0.180 ppm U, 25 ppm U). Under the @Risk program simulation used in one of the three scenarios reported here, the

68 It is customary in conducting probability modeling to use a uniform probability distribution when it is uncertain what the actual probability distribution is in the case concerned. In exploration terms, completion of a single mineralized drill hole within any given year signals initial discovery of an economically-mineralized breccia pipe ore body, while the completion of 60 drill holes in a year would represent completion of all of the pre-mining surface exploration delineation work on that ore body.


average concentration of uranium in drilling-related leachate was randomly determined using the Uniform simulation function assuming uniform distribution of leachate uranium concentrations, varying randomly from 0.180 ppm U (the average concentration of uranium estimated to be coming out of the Orphan Mine) to 25 ppm (the maximum concentration of uranium present in uranium-sulfate solutions derived from uranium- and sulfide-mineralized ore in a carbonate environment).

5) Other constants used in the simulation included: 5000 gallons of drill water used

per economically-mineralized drill hole; 3.785 liters/gallon; and 1,055 square miles -- the area C and F exploration and mining area proximal to and including the projects of the Proposed Plan of Operations.

Three different @Risk simulations were run using the above model set-up in Excel, each at 50,000 Monte Carlo iterations in order to test the sensitivity of the model to the concentration of uranium in drill water ore body leachate. The first simulation assumed a maximum drill water leachate concentrations of 25 ppm U average concentration. The second assumed a range of concentrations would exist for the drill water leachates, varying from 0.180 ppm to 25 ppm U, and the third simulation assumed the apparent Orphan Mine natural recharge leachate concentration of 0.180 ppm U would be representative of the water uranium concentrations reached by drill water passing through and over economic grades and thickness of breccia pipe uranium mineralization discovered in areas C and F. Figures 37, 38, and 39 show the @Risk descending cumulative frequency diagrams for each of the three simulations. Table 33 provides the estimated probability that 1650 kg or more of uranium would be annually released to the Redwall-Muav aquifer under each ore body leachate concentration scenario. Again recall that 1650 kg is the threshold value of dissolved uranium that would be required to be added annually to the spring-fed Havasu Creek dissolved uranium load to raise uranium (and related gross-alpha radiation) concentrations up to the EPA MCL.


Figure 37. 25 ppm U solution worst-case scenario.

There is less than a 0.3% probability that more than 1650 kg of U would be annually added to Havasu Creek under this worst case scenario of uranium leachate concentration, even under highest uranium price conditions.

Figure 38. 0.18 to 25 ppm U solution scenario.

There is less than a 0.1% probability that more than 1650 kg of U would be annually added to Havasu Creek under this leachate uranium concentration scenario, even under highest uranium price conditions.


Figure 39. 0.18 ppm U solution (Orphan Mine) scenario.

There is no (0.0%) probability that more than 1650 kg of U would be annually added to Havasu Creek under this scenario, even under highest uranium price conditions.

Table XXXIII. Results of Monte Carlo Simulation of Effect of Mineralized Breccia Pipe Exploration Drilling in Areas C and F on Redwall-Muav Aquifer Ground

Water: Sensitivity to Leachate Uranium Concentration

Simulation’s Drilling Water Leachate Uranium Concentration

25 ppm U

0.180 to 25 ppm U

0.180 ppm U

(Orphan Mine Case)

Probability that 1650 kg/year or more of uranium is added to Redwall-Muav Aquifer

0.3%

0.1 %

0.0 %


The true probabilities of the 25 ppm U and 0.180-25 ppm U leachate secnarios would

be materially less than indicated by the numerical modeling work due to the influence

of the following factors not contained in the simulation models because of the difficulty

in representing them numerically:69

1) A sufficient number of successful exploration programs located within areas C

and F could be drilled each year to begin the mobilization of a total of 1650 kg or more of uranium from economically-mineralized breccia pipes down into the Redwall-Muav aquifer under foreseeable uranium price levels. However, because the average residence times of Redwall-Muav aquifer ground waters vary widely from about 4,000 to 10,000 years within areas C and F, it is extremely unlikely that each project’s mobilized uranium would reach the Havasu Creek area at the same time as the uranium solution contributions from each of the other projects. A coincidence in time of arrival of each project’s dissolved uranium bolus would be necessary to raise Havasu Creek uranium levels up to 30 ppb at some point in the far future.

2) The variation in length of horizontal travel distance from potential exploration

project sites within exploration areas C and F would have, in part, the same general probability-decreasing influence on elevated Havasu Creek uranium concentration as factor #1 above. In addition, the 20 to 70 mile long horizontal travel paths from the area C and F exploration projects to the Havasu Creek springs would provide the ground water’s dissolved uranium load with material opportunities to chemically react with, and absorb to, the mineral framework of the Redwall-Muav aquifer. Interactions between dissolved solids like uranium and the aquifer mineral framework would have the effect of lowering the uranium concentration of Redwall-Muav aquifer ground water before the water reaches the surface again in the Havasu Creek drainage, and thus decrease the probability that Havasu Creek dissolved uranium levels would reach the 30 ppb EPA MCL in the future. Canyon Mine EIS (1986) baseline determination of the high Havasu Creek 234U/238U ratio indicates considerable water-rock uranium interactions in the water emanating from the Redwall-Muav springs there (Fitzgerald 1996, p. 74).

3) The numerically-modeled and simulated Figure 34 model presupposes that

ground water deposited into the Redwall-Muav aquifer in and around areas C and F has no avenue of natural exit except through Havasu Creek. As the USGS (2005, p. 44) remarks, some Redwall-Muav ground water exits the Redwall-Muav aquifer through the underlying older rocks. The USGS has expressed no idea how significant this avenue of ground water discharge is in the Coconino Plateau region. Discharge of uranium-bearing Redwall-Muav aquifer ground water through basement rocks underlying the aquifer would have the effect of decreasing the amount of uranium discharged into the Havasu Creek drainage.

69 The effects of the first two factors were acknowledged in the 1986 Canyon Mine EIS. See pp. 4.36-4.42 of that EIS. The third factor was not mentioned in that EIS, however, presumably because the USGS had not completed its 2005 report on Coconino Plateau hydrology yet.


From the above modeling work, it appears that there is a remote (0.3% or less) chance that modern day exploration drilling in areas C and F of Figures 33, and 35- 36 would, in the far future, raise the dissolved uranium levels of Havasu Creek up to the EPA MCL of 30 ppb uranium. Note that this 0.3% or less chance for Havasu Creek contamination

would only occur in the event that the uranium price level reaches and stays at

historically extreme values and uranium exploration activity reaches unprecedented

heights. In contrast, in the event that drill circulation water descends to the Redwall-Muav aquifer from economically-mineralized pipes with uranium concentrations of the magnitude apparent at the Orphan Mine breccia pipe, then it appears exploration drilling in areas C and F would have no different effect on Havasu Creek drinking water quality than would be the case under the No Action Alternative. In order to minimize the remote chance of future drinking water contamination of Havasu Creek waters by uranium possibly mobilized during areas C and F exploration drilling, it is recommended:

1) That mining companies reduce, whenever possible, their use of drilling water while drilling exploration drill holes in breccia pipe exploration targets that have been identified as containing economic concentrations of uranium. By reducing water-utilizing core drilling of ore zones for the purposes of mine planning and gamma log calibration to the minimum level practicable for those purposes, and otherwise only using water during drilling work where necessary to overcome difficult drilling conditions, considerable risk of future uranium contamination of the Havasu Creek waters can be avoided.

2) That the possibility of employing humic acid drilling additives as a means of

reducing hydraulic conductivity70 and uranium mobility within and around mineralized breccia pipes be further investigated and possibly tested for application to the exploration drilling of the uranium-mineralized collapse breccia pipes of northern Arizona. Humic acid drilling additives were briefly discussed in footnote #51 on page 108 of this report.

Cumulative Impacts on the Economically-Disadvantaged

In the event that uranium exploration and mining work is permitted to continue in Coconino County, the long-run effect on the Coconino County labor market that contains the county’s economically-disadvantaged will be to increase demand for labor. Increased demand for labor like that generated by a newly entering industry such as mining would raise the general wage level of Coconino County, but would especially have this effect on those who are a part of the labor market for skilled and unskilled labor. See Headwaters Economics, November 2008, p. 24, for description and discussion of a moderately similar

70Hydraulic conductivity is a measure of the speed that ground water moves through rock under the influence of gravity as a function of the ground water viscosity and density. With regard to the use of humic acids – breccia pipe fractures and permeable matrix sealed – or partially sealed – by sulfuric acid-precipitated humic aids would reduce water inflow and outflow over the uranium ore contained in a pipe. This theoretically should reduce the amount of uranium carried away from the pipe and down into the Redwall-Muav aquifer.


occurrence of this effect.71 Figure 40 from Headwaters Economics, September 2008, illustrates the direct, indirect, and induced per capita income gained by those working in energy-focused counties over those employed in their peer western US counties not including significant energy development in their economic mix. The 1973-1993 (20-year) area of personal income creation under the energy-focused county curve and above the peer counties income curve is 3.8 times greater than the 1995-2005 (10-year) slight undershot that follows. This means that the people in the energy- (and mineral-) producing western counties gained 3.8 times the wealth during the 20 production years than they ‘under-earned’ in the ensuing 10 non-producing years. Figure 40 clearly illustrates that inhabitants of western US energy-focused counties strongly out-earned the people living in the peer, non-energy focused western counties from 1970-2005. The Figure 41 example from western Colorado (Headwaters Economics, November 2008) shows that the greatly increased per capita income effect extends and multiplies from the mining/energy industries out to those working in the construction, professions, and services industries in the same county. Under the No Action Alternative, the Proposed Plan of Operations work with the goal of helping to establish a viable uranium mining industry in Coconino County would be delayed, if not halted. Therefore, following the No Action Alternative would have the opportunity cost72 of maintaining the current economically-disadvantaged positions of many of those residing in Coconino County.

71 “Impacts of Energy Development in Colorado, with a Case Study of Mesa and Garfield Counties” at http://www.headwaterseconomics.org/energy/HeadwatersEconomicsImpactsofEnergyCO.pdf. A general discussion of the pros and cons of fossil fuel energy industry development in the rural West, titled, “Fossil Fuel Extraction as a County Economic Development Strategy” by the same nonprofit group can be found at http://www.headwaterseconomics.org/energy/HeadwatersEconomics_EnergyFocusing.pdf. Note that the rapid rates of development of energy source development possible with oil and gas are not at all feasible with conventional metals or mineral fuels mining. Consequently, community socioeconomic impacts are far less abrupt than those experienced in communities close to oil and gas development. 72 An economics term referring to what is automatically lost when taking one decision over another.


Figure 40. Comparison of per capita income gain between the labor markets of fossil energy-focused western US counties and those western US counties without fossil energy (and mineral) industries.

Cumulative Impacts of Breccia Pipe Mining on Coconino County

Introduction Although the completion of the exploration work contained in the Proposed Plan of Operations is not a guarantee that the uranium prospects concerned in the Plan would be developed into uranium mines, work of the sort proposed by the Kaibab Joint Venture and by other operators in the same area should eventually lead to additional uranium mine development in Coconino County. This being the case, the uranium exploration work covered by this Proposed Plan of Operations could be said, probabilistically speaking, to have an incremental cumulative mining impact on Coconino County. For planning purposes the Canyon Mine EIS (1986)73 considered that an additional three breccia pipe mines, besides the Canyon Mine, would be developed south of the Grand Canyon in the years closely following start-up of the Canyon Mine. The 1978-1988 Table XXXII 95% confidence interval for mine start-ups/square mile/year, suggests that the 1,155 square miles of USFS, private land, and State Trust lands identified in Figure 33 (areas B, C, and F) as being prospective for economically-mineralized breccia pipes could host discovery and start-up of 3 to 20 new uranium mines over the next 20 years. Expected or mean value of mine start-ups for the next 20 years in the south of the Grand

73 The 1986 Canyon Mine EIS has been scanned and is posted for downloading at http://public.dirxploration.fastmail.us/.


Canyon areas B, C, and F, using the 1978-1988 data to project discovery and mine development, is eleven (11) new mines.

Figure 41. Mesa County, Colorado, illustration of per capita income growth in mining, construction, and services and professions caused by 1974-1989 mining industry activity.

The Canyon Mine EIS assessment of cumulative impacts for a maximum of four simultaneously-operating mines south of the Grand Canyon with the intention of providing “…an accurate basis for assessing the impacts of similar proposals in the future” (1985, p. 4.2, paragraph 1). The EIS divided cumulative impacts into two categories: Minor issues of concern according to the Canyon Mine EIS scoping process, and major issues of concern according to the Canyon Mine EIS scoping process. The cumulative impacts analysis in the Canyon EIS assessed maximum potential impacts of both the minor and major issues of concern by assuming that all mines will be producing at a maximum production rate of 200 tons per day, and that each will operate for a period of 5 to 10 years. Minor issues of concern In the case of any given mine and its minor issues of concern, including the Canyon Mine, the mine development and its operation would (assuming all possible mitigation and avoidance measures being taken) have the effects listed in Table 34.


Major issues of concern During the Canyon Mine EIS scoping process, the following matters were identified as being major concerns to stakeholders other than the Canyon Mine proponent:

• Social and economic impacts of uranium mining on local communities and Coconino County;

• Wildlife;

• Visual impacts;

• Air quality;

• Transportation routes;

• Impacts on soil and water resources; and,

• Impacts on Indian religious concerns.

A. Social and economic impacts of mining The Canyon Mine 1986 EIS projected the probable socioeconomic impact of the operation of the Canyon Mine on Coconino County using the USFS-developed economic modeling program, IMPLAN (Impact Analysis for Planning). Using demographic and economic statistics of Coconino County as inputs, along with estimates of wages, capital investments, taxes, etc., derived directly from the Canyon Mine, IMPLAN provided estimates of indirect and induced changes in employment, salaries, and total production of Coconino County as a result of eventual operations at the Canyon Mine. The 2008 constant dollar estimates of ten-year operating expenditures provided by the Canyon Mine’s original owner, Energy Fuels Nuclear, Inc., as inputs to the IMPLAN program were these:74

1) Wages and fringe benefits $20,450,000 2) Plant and equipment 6,130,000 3) Mining supplies 30,670,000 4) Ore haulage to Blanding, UT 8,180,000 5) Sales and use taxes 1,227,000 6) Mineral severance taxes 3,480,000 7) Property taxes 2,607,000 8) Energy usage

Electricity 4,090,000 Diesel fuel 920,000 Ten-Year Total Expenditures $ 77,754,000

Mine-related expenditure inputs to the economy-at-large which are not included in the above table were state and federal income taxes, license fees, motor vehicle taxes, motor

74 Converted from 1984 dollars to 2008 dollars using the urban consumer price index.


Table XXXIV. Cumulative Impacts of Mining-Related Minor Concerns

Environmental

Attribute

Environmental Impact

of Canyon Mine

20-year Impact (~11

mines = expected value) 75

Wetlands, floodplains, prime

farmlands

None

No effect

Grazing capacity

5-8 animal unit months

lost – insignificant

55-88 animal unit months

lost

Timber

900 to 76,500 board-feet lost (road-building) –

insignificant

4,500 to 382,500 board feet

lost.76

Other vegetation

15-20 acres – no impacts after reclamation after 5-10

years.

165-220 acres

temporarily disturbed.

Environmental

Justice

No minority groups and women will be adversely

affected by the mine development, other than potentially through surface water matters concerning

the Havasupai Reservation. See this report for Havasupai Reservation ground water concerns.

Economically-disadvantaged would be benefited by mine development.

As in the Canyon Mine

case. See this report above for assessment of potential cumulative ground water

concerns derived from pre-mining exploration drilling.

Recreation

Solitude temporarily impacted as result of noise,

haulage road traffic, mine activity. The improved road access to the mine locally improved recreational

[and fire-fighting]access.

Mines that require new road

construction will temporarily harm solitude but increase recreational

access.

Noise

Passersby to mine will notice acceptable noise level. Highway 64 travelers will hear nothing significant.

Mine workers will intermittently and rarely be exposed to high noise levels.

This localized noise will cease after 5-10 years

Mine workers and passersby

to mines will each experience the Canyon

Mine case for 5-10 years. Effect on highway travelers will vary with location of

future mines.

75 Using relative areas of private-state and USFS lands, it would be expected that a little over half (6/11) the future mines would be located on (usually unforested) State and private lands of area F, and a little fewer than half (5/11) would be located on (usually forested) USFS-administered ground. 76 Lower elevation (drier) State Trust Lands and private lands are assumed to be largely unforested.


Table XXXIV. Cumulative Impacts of Mining-Related Minor Concerns, Continued…

Environmental

Attribute


of Canyon Mine

20-year Impact

(~11 mines expected)

Impacts on Mine

Workers

Radiation exposure would be less than weekly guideline of 100 millirems; radon exposure is

expected to be about 2.2 working level months (WLM) per year. Occupational radon progeny

limit is 4 WLM per year. Cumulatively speaking, studies indicate a cumulative 100

WLM value is associated with increased rate of lung cancer. EPA has suggested, however, risk of lung cancer may increase over the cumulative

range of 20-100 WLM.

Per worker case same as

Canyon Mine case.

Cultural Resources

Cultural resources at minesite, newly

constructed road, road improvement or maintenance, powerline construction, wildlife

mitigation activities will be avoided or recovered if National Register eligible.

All cultural resources will

be identified prior to operations, then avoided or

recovered if National Register eligible.

Short Term Land Use and Maintenance and Enhancement of Long

Term Productivity

Canyon Mine production is planned to last from

5-10 years, therefore there would be no long- term commitment of land resources to the

mining effort. Acres improved to offset loss of wildlife habitat through mine development and

road development for ore transport are long term commitments that will maintain and enhance

long term productivity.

Multiples of the Canyon

Mine case.

Agency Financial

Burdens

At the time of writing, the Canyon Mine

operation would not create increased needs for police, fire, or emergency medical protection. Construction of new off highway haul roads would be the responsibility of mine operator.

No material increased financial burdens would be placed on Coconino County or the local

communities, although if significant labor needs are filled by out of area hires, their immigration

may cause marginal increases in local community financial burdens.

According to the Canyon

Mine EIS, in the event one or more additional mines are

started in areas B, C, & F, then the excess capacity, if

any, of services provided by local governments will be used up and expansion of

some services may be required.


Table XXXIV. Cumulative Impacts of Mining-Related Minor Concerns, Continued…

Environmental

Attribute


of Canyon Mine

20-year Impact

~11 mines expected

Conflicts with Other

Agency Plans or Policies

At the time of writing the Canyon Mine EIS,

there were no known conflicts with other Federal, State, or local government plans,

policies, or regulations.

Currently, management of Coconino County, Grand

Canyon National Park, and the Arizona State Lands

Department are all evidencing explicit or tacit resistance with regard to continued uranium mine

development in Coconino County.

Energy

Energy requirements are a function of vehicle

use and mine operation. Mining of uranium will yield net gain in energy.

Net gain in energy is some

multiple of the Canyon Mine case.

carrier taxes, fuel taxes, as well as like fees and taxes incurred by mine workers and their families, mine suppliers, and contractors. In the 1986 economic impacts analysis, it was expected that Williams, Arizona, would feel the economic impacts from the development and operation of the Canyon Mine most directly. Lack of housing and labor pool in Tusayan would mean that the mine’s 10-35 person labor needs would have to be filled elsewhere, most likely from Williams. Canyon Mine EIS IMPLAN modeling indicated that around 58 new jobs would be created in the Williams area once the mine reached its full production capacity, and about 100 jobs throughout Coconino County. Assuming a maximum ten-year mine operating life, this means that, county-wide, around 1000 job-years would be attached to the Canyon Mine. According to indexed EIS estimates, the total annual income of Coconino County would be increased by about $6,130,000 (2008 dollars) from operation of the mine. Cumulatively speaking, development and operation of the expected eleven additional breccia pipe mines over the next twenty years would therefore translate to approximately 1,100 additional jobs for another 10,000 job-years. In the event that up to twelve mines were operating simultaneously in Coconino County, the Canyon Mine IMPLAN model indicates that total added annual income in the county would amount to around $67,400,000 (2008 dollars). In a useful comparison, this amount is almost 6X’s the


amount of annual income and 3X’s the full-time equivalent jobs added to the regional economy by the Grand Canyon commercial rafting industry (Hjerpe and Kim, 2006).77 The Canyon Mine EIS did not envision any necessary increase in the population of Williams in order to accommodate hiring related to the mine, given the available labor pool there in 1986. Because existing Williams support facilities like schools had not operated at capacity for many years, it was not expected that Canyon Mine operations would require immediate expansion of the community plant, and that little or no change in the social structure or lifestyle then present in the town would occur. Overall, according to the EIS, it was anticipated that any socioeconomic changes that might occur in Williams as a result of the opening and operation of the Canyon Mine would be positive because of increased employment levels and consequent improvement in the relative standards of living. Because of the falling per capita income and increased unemployment levels in Williams since then (p. 91, this report), it is expected that these benefits would still accrue once the mine is opened and put into full operation. In considering cumulative socioeconomic impacts, the Canyon Mine EIS judged that Williams could easily accommodate the services needs attached to personnel operating a second mine in the Coconino County area south of the Grand Canyon. It was believed, however, that as the number of mines increased beyond that point, new government and private services would be required. Note that -- unlike in the very recent case where coal bed methane production in Colorado and Wyoming has expanded so rapidly78 that local communities have been strongly stressed by the need to accommodate rapid influx of workers and their families, and have had to cope with the unexpected extreme wear and tear on community and regional infrastructure, and the very broad impact on the natural environment (see Figure 42) -- breccia pipe uranium exploration and production is a much more gradual development process that would permit gradual community adjustment to a gradual and relatively minor growth in population. As this report shows, impact of the natural environment by uranium exploration and mining is very narrow and comparatively minor. A cumulative positive socioeconomic effect of the gradual development of a breccia pipe uranium mining industry not mentioned in the Canyon EIS is related to the current economic recession. According to historical econometric research recently conducted by

77 Of $21,000,000 annual 1999 dollars income from commercial rafting, 57% is lost to leakage to surrounding states and their counties. In 2008 dollars (CPI-U indexed), annual commercial rafting income, then, is about $11,500,000. IMPLAN modeling by Hjerpe and Kim indicates that direct and indirect employment in the Grand Canyon region derived from Grand Canyon commercial rafting is 357 full-time equivalent jobs. See Table 4 of Hjerpe and Kim, 2005. 78 A new coal bed methane production well in Colorado or Wyoming can be brought into production within 6 months, while a new breccia pipe uranium mine requires 1-4 years to discover and drill explore, 3-5 years to plan and construct, and then operates for 5-10 years thereafter. And, according to Headwater Economics (11/08), there are currently 7,500 producing wells in western Colorado alone, with 50,000 additional wells expected in the next 30 years. Each methane well is reported to produce for only about 3 years.


Kuhlmann et al., 2008,79 “…states that are becoming [industrially] more diverse have recessions of shorter duration. In states where diversity is decreasing, recessions are longer in duration. …this could mean that as long as a state can accelerate its industrial diversification, they may be able to reduce the duration of their recessions.” Under the No Action Alternative, the opportunity costs of not approving operations supporting the discovery of additional mineable uranium ore bodies in Coconino County would include:

1) Tusayan Ranger District and the general Valle-Williams areas would remain home to the current economic and associated social structure dominated by the relatively low-paying tourism industry, and not become host to an industry distinctly known for high-paying jobs (Figure 43).

2) Coconino County and the state of Arizona would not be able to begin to avail

themselves of a ready opportunity that would apparently locally reduce the duration of the current recession by timely increasing the degree of industrial diversification contained in Coconino County.

79 Kuhlmann, Angela, Decker, C.S., and Wohar, Mark, 2008, The composition of industry and the duration of state recessions: The Journal of Regional Analysis and Policy, 38(3), pp. 206-221, available for download at http://www.jrap-journal.org/pastvolumes/2000/v38/F3831.pdf.


Figure 42. An example of what northern Arizona breccia pipe uranium exploration and mining is not: Extremely rapid growth of the coal bed methane industry in western Colorado.

From Headwaters Economics, November 2008.


Figure 43. Energy-focused Counties of the western USA: mining industry wages in context.

From Headwaters Economics, September 2008.

B. Mining impacts on wildlife In the case of the Canyon Mine itself, no adverse effects to threatened, endangered or sensitive wildlife species were identified at the mine site during the studies leading up to the Canyon Mine EIS. Removal and stockpiling of topsoil during mine construction temporarily eliminated approximately 17 acres of grassland habitat. According to the EIS, this grassland habitat disturbance had the greatest effect on small mammals and reptiles as their home ranges were mostly or entirely within the mine site area. However, it was not believed that the regional viability of the affected species was threatened by this disturbance in light of total population numbers in the region, and in light of the large area of habitat otherwise available to these non-game species. Once the mine goes into operation, it is expected that these operations will disrupt elk use of the 32 acres grassland opening in forest cover that marks the Canyon Mine site. This 32 acre grassland area represents temporary reduction of about 0.14 percent of this grassland type in the Tusayan District. Eventual Canyon Mine ore haul traffic along the graveled ore road leading south and west to highway 64 will probably disturb elk to some degree within ½ mile of that road. Besides the approximately 9 acres of vegetation clearing along the 3.6 miles of new mine haul road construction, this noise and traffic disturbance is expected to reduce intensity of elk use of about 228 acres of elk calving habitat, an impact that is expected to


incrementally reduce the currently rapid growth of the elk population on the Tusayan Ranger District. The remainder of the preferred haul route is along established highways is anticipated as exerting minimal added impacts to wildlife and its habitat. Similar disturbance of habitat and wildlife is, according to the Canyon Mine EIS, expected in the event that additional mines are opened in Coconino County. In general, wildlife and wildlife habitat will be impacted only at the mine site concerned and along haul routes to those mines. Degree of impact in any given case will be determined by location of the new mines with reference to habitat. Using the Canyon Mine as a model for future mine site wildlife and habitat disturbance, 15-20 acres of habitat disturbance can be expected at each new mine. Relative locations of new mines will govern the amount of new mine road construction required to support mine operation. Proximal mines should be able to share access roads, an economy of scale that would minimize habitat and wildlife cumulative impacts. According to the Canyon Mine EIS (p. 4.18), granted proper mitigation, “…the impacts of one additional mine in the Tusayan area or three additional mines in Coconino County south of the Grand Canyon would not be expected to be significant unless mining operations and haul routes are concentrated in critical habitat.” In the Canyon Mine case, the No Action Alternative with reference to that proposed mine operating plan would have had no impact on the wildlife population or its habitat. The habitat at the mine site and along the ore haul route would have remained fully utilizable by wildlife, but any beneficial impacts associated with the mitigation measures contained in the preferred EIS alternative – namely, replacement of habitat and water sources – would have been abrogated.

C. Visual impacts of mining Under the preferred haul route objective, visual impacts from the Canyon Mine construction and operation are largely short-term reversible alterations of the scenic quality of the viewed landscape, alterations derived from the presence of project-related equipment and machinery at the mine site, vehicle traffic and power line construction along the off-highway portions of the ore haul route, and related changes in vegetative cover. Reclamation work will restore the mine site to its pre-mining state. Visual quality of the Grand Canyon miles north of the Canyon Mine has not been affected by the mine construction. The mine development is visible to people driving directly up within half-mile to the site, however, and to over-flying aircraft. According to the Canyon Mine EIS (p. 4.19), “Impacts on visual quality will be site specific and no cumulative impacts are expected from the potential development of additional mines.”

D. Impacts of mining on air quality Modeling in preparation of the Canyon Mine EIS of Total Suspended Particulate (TSP) concentrations of dust raised by mine operations and ore truck operation under the most


extreme meteorological conditions indicated that no significant air quality impacts would arise in the Grand Canyon National Park as a result of operations at the mine and ore haul routes. Once the mine is put into operation, radon gas will emanate from ore stockpiles and from the mine vent stack. Radon and its daughter products will be rapidly carried away by wind and breezes, diluting and dispersing concentrations of radon and its products. Due to the rapid decay rates of radon progeny, these progeny quickly become of no concern. Modeling of expected radon levels from sources at the Canyon Mine with respect to potential directions of wind flow across the mine site showed that residents of Tusayan, for an impact example, might be exposed to a 2-10 percent fluctuation in natural radon levels as a result of Canyon Mine operations. These potential mine-related changes in radon levels are, according to the Canyon Mine EIS, indistinguishable from natural fluctuation in radon levels. Uranium and its progeny will be present in dust blown off ore stockpiles, as well as in mine dust coming out of the mine exhaust vent. However, Canyon Mine EIS modeling of radioactive dust dispersal from the mine site showed that radioactive dust dispersal from operations there will be 300 times less than the levels permitted by the Nuclear Regulatory Commission at licensed uranium ore milling facilities. No radioactive dust is added to the atmosphere from ore-hauling, as the ore truck loads are always tightly covered with tarpaulins. According to the Canyon Mine EIS, each additional mine would contribute 25 to 30 tons of Total Suspended Particulates (TSP) per year, and each mile of haul road would add 35 to 40 tons TSP each year to the atmosphere. At these dust-raising levels, unless an additional mine was located within a few miles of the Canyon Mine, there would be no cumulative impact on the dust levels of the area and no air quality standard violations would be expected. In such cases where more than one mine uses the same ore haul route, mitigation measures like use of water, calcium chloride, or paving might be necessary in order to avoid violation of air quality standards. The Canyon EIS study showed that radiation impacts from breccia pipe uranium mines are localized, site-specific. Airborne radioactivity dilutes and disperses to insignificant levels within a short distance from any given mine site. According to the EIS (p. 4.26), “Three additional mines in Coconino County [besides the Canyon Mine] would not make a significant contribution to cumulative levels of radiation in the county. Impacts would be localized near the mine sites.” In the event that development and operation of the Canyon Mine had been denied under the EIS No Action Alternative, radon gas and dust levels would have remained at background levels. In addition, fuel that is a perfect substitute80 for the burning of coal in the generation of electrical power would remain unavailable to human use. Electricity

80 In economics, a “perfect substitute” for some product or service is one that works just as well as the product or service being substituted.


generated using nuclear power has, in contrast to the like use of coal and natural gas, no atmosphere-polluting waste byproducts.

E. Mining impacts on transportation routes Traffic on Tusayan Ranger District roads is generally low, with fluctuations occurring locally during resource-related events like hunting seasons, fires, and USFS project work activities. According to the Canyon EIS, studies have established that road improvements like those associated with breccia pipe uranium mine development and operation stimulate casual use of those roads by about 20%. In the Canyon Mine case, the off-highway maximum haul road use will correspond to maximum ore production rate of 200 tons of ore per day. At this full production rate, 10 trucks would leave the mine site for the Blanding, Utah, mill daily. It is possible that an ore truck accident could occur anywhere along the Canyon Mine to Blanding ore haul route. During the 1970s-1980s uranium mining period, the ore trucks of Energy Fuels Nuclear, Inc., traveled (as of 1985) about 6,600,000 total miles with five spills of ore (1 spill per 1,320,000 miles traveled). In only a single event was the amount of ore spilled greater than 2 tons (>1 cu. yard), and in all five cases all spilled ore was recovered immediately with no residual radioactive material left behind. Mitigation measures associated with ore haulage from the Canyon Mine are that the appropriate federal and state authorities be notified and that the spilled ore be cleaned up and removed immediately. When rare spills occur on Indian reservations, tribal authorities are also to be notified. In the unlikely event of an ore truck spill, animals and people passing by the accident site would be briefly and harmlessly exposed to “extremely low” (Canyon Mine EIS, p. 4.27) levels of radioactivity until the spill is removed. The Canyon Mine EIS remarks that normal spill clean-up techniques might not be effective in occurrences where ore is spilled into moving surface water, and that ore that is not removed from a stream or river could create a temporary increase in stream particulates and extremely low-level radioactivity. Given the extremely low incidence of streams and rivers along the northern Arizona and southern Utah ore haul routes, the probability of such an occurrence is extremely low, however. Cumulative impact of additional uranium mines in central Coconino County as far as haul route accidents are concerned would be to increase the number of road miles traveled by ore trucks per year. All other things being equal, such an increase would increase the random average frequency (not the road mile incidence, however) of spills in time as a function of the increase in number of mines and consequent number of ore trucks on the road. In addition to this effect, improvement of off-highway roads to new mines would also tend to increase the casual use of the back country road system across the isolated State Trust, private, and USFS lands south of the Grand Canyon.


F. Mining impacts on water and soil resources Located at the base of Skinner Ridge, parts of the Canyon Mine site are subject to shallow flooding during extreme runoff events. In response to this flooding risk, a number of alternative methods were proposed and considered as means to funnel storm runoff away from the mine site in order to minimize the probability of loss of ore material temporarily stockpiled at the surface of the mine. The preferred alternative put into effect during the construction of shaft, head frame, and yard at the Canyon Mine minimized surface disturbance by using stockpiled topsoil and other excavated material to build a mine-encircling dike capable of protecting the mine site from everything up to 500-year flooding event.81 See pp. 4.31 to 4.36 of the Canyon Mine EIS. In the unlikely case of a 500-year flood event and the Canyon Mine dike protection is overcome, and runoff water then mobilizes some of the ore and mine waste material temporarily stored at the surface of the mine site, the Canyon Mine EIS determined that the suspended and dissolved material carried in runoff that was picked up at the mine would be reduced by at least 70% by 2 miles below the mine, and by at least 98% some 13.5 miles below the mine. Field evidence indicates that active runoff from flooding in the watershed containing the Canyon Mine proceeds no further than 18 miles down drainage from the mine. Cessation of the storm event causing flooding, infiltration of flood water into soils and sediments underneath the drainages, and evaporation, all limit the down drainage extent of flooding. Unevaporated water infiltrating into underlying soils and rocks eventually migrates downwards and recharges the Redwall-Muav aquifer, the aquifer that itself feeds the seeps and springs feeding into the Colorado River drainage. In summary, the EIS concluded with regard to the impact of the Canyon Mine surface operations on ground water quality (p. 4.36):

• Due to dilution, concentrations of dissolved radioactive materials in runoff would be small in floods sufficiently large to cause failure of the proposed drainage controls;

• The initial low concentrations of radioactive minerals would be decreased significantly via chemical precipitation and hydrodynamic dispersion in the subsurface;

• The probability is small that a flood sufficiently large to cause failure of the proposed drainage controls would occur during the approximate 10-year period from the first intersection of ore by mine openings to the end of reclamation operations; and,

• According to the [Canyon Mine] Plan of Operations, retention ponds for localized on-site storm runoff and for captured mine shaft drainage will be lined to prevent seepage.

Hydrological and hydrogeochemical modeling (pp. 4.36-4.41) of the worst case impact of subsurface mining operations conducted in preparation of the Canyon Mine EIS came to the same general conclusion: Underground operations would have no significant impact on possibly

81 Peak flow of 352 to 1329 cubic feet of runoff per second at the mine site.


present perched aquifers and on the ground water contained in the Redwall-Muav aquifer underlying the Canyon Mine. As a failsafe of the Canyon Mine EIS analysis and planning work, a monitoring well was drilled into the Redwall-Muav aquifer by the original project proponent, Energy Fuels Nuclear, Inc. This well was intended also to be used as a supply well (5 gallons per minute) for mine operations. The Canyon Mine EIS states (p. 4.41) that no radiological impacts were expected on the soils at the mine site and along the haul routes. A monitoring plan had been designed to make certain the conclusions reached in the EIS were accurate with regard to potential soil contamination during mine operations. It was expected, according to the EIS, that following reclamation at the Canyon Mine, the 17 acres or so of soils disturbed by the mine construction and operation would be near pre-mining productivity levels within 3 to 5 years after completion of the reclamation work. Surface water control features of the Canyon Mine plan were designed to prevent ore and waste stockpiles from contaminating surface water, even under extreme flooding conditions (Canyon Mine EIS, 1985, pp. 4.41-4.42). As these flood control features limit unlikely extreme flooding impacts on surface and subsurface waters to the immediate proximity of the mine, the development and operation of additional mines south of the Grand Canyon generally would not create any cumulative impacts on surface water or ground water. However, in the case where a second mine is constructed in the same drainage system as the Canyon Mine, and both mines experience a simultaneous failure of their flood control features from a maximum flood event, the Canyon Mine EIS preparers warn that released surface waters would contain gross-alpha and Ra-226 concentrations in excess of EPA drinking water standards. Fortunately, according to the EIS, these concentrations would disperse and dilute rapidly, and any remaining radioactivity in the soils and stream sediments would be cleaned up by the mine operators immediately after the discharge. As is the case with the increase in incidence in time of rare haul truck accidents with increase in number of operating mines in Coconino County, the preparers of the Canyon Mine EIS expected that the slight risk of flood water release of radioactivity to the surface environment could increase along with the number of mines operating in the area. Nevertheless, these authors believe (p. 4.42) such possible radiological impacts on surface and ground waters would be localized near each of these additional mine sites, as expected in the Canyon Mine case. Mitigation measures like those planned for the Canyon Mine, including monitoring wells and pumping water from mineshafts would insure that there would be no increase in ground water radioactivity from any of the additional mines.

G. Mining impacts on Indian religious concerns The remarks of the Canyon Mine EIS (1986, pp. 4.42-4.44) remain germane to mining impact on Indian religious concerns. For this reason, the relevant portions of this EIS are here excerpted in their entirety. Speaking of the opportunity costs and effects of not permitting mining development at the Canyon Mine site, the EIS states:

Implementation of the No Action Alternative would create no additional impacts on the religious sites or practices of American Indians. Indian concerns about potential impacts on unidentified sacred sites, sacred springs and hunting and gathering, and conflicts with traditional beliefs would be alleviated for the Canyon Mine proposal, but not for other activities in the region.


Enumerating the specific impacts of the Canyon Mine on Indian religious concerns in the Canyon Mine area, the EIS explains:

Construction and operation of the Canyon Mine will have no impact on Indian lands in northern Arizona. Traffic on US Highway 89 across the Navajo Reservation will increase by approximately 20 ore truck trips per day, but given existing traffic levels, that increase is insignificant. The Hopi and Havasupai Tribes have expressed concern about possible water quality impacts at Blue Spring and Havasu Springs. Both springs discharge from the Redwall-Muav aquifer which is located below the mine site. The aquifer is well below mine shaft depth and no impacts are expected. In addition, movement of subsurface water to and in the Redwall-Muav and toward the springs is extremely slow and significant dilution over time and distance is anticipated. Finally, Alternatives 3-5 [the plan alternatives followed in constructing the mine] include a ground water quality monitoring well which is expected to identify any contamination and allow mitigation, thus preventing any threat to either Blue Spring or Havasu Spring. After communications and consultation with Hopi and Havasupai Tribal leaders and experts on Indian religious sites and practices as well as an archeological investigation of the mine site, no specific Indian sacred or religious sites have been identified near the mine site. The Tribes maintain that Indian religious interests will be adversely affected but have not identified specific sites which are threatened. In addition, a review by an expert in Indian religious sites and practices has failed to identify sites that would be affected by the proposed action. Consultation with tribal leaders will continue. Certain sites and areas with religious significance have been identified and evaluated. The area near Tusayan has been historically used by the Hopi to gather turkey feathers and sacred herbs for religious and ceremonial purposes. The loss of the mine site and the additional traffic and activity in the area will reduce the area available for these practices but should not impose a significant burden on these occasional uses and will not prevent the Hopi from continuing these practices on National Forest lands. Mine development will not affect Indian access to the area nor materially restrict the present level of religious activities. The mine site is only one small part of a large area available for Indian religious activities, and development of the mine will not burden traditional Indian religious beliefs. Some areas near the haul routes are also used for gathering purposes, including the Little Colorado River near the bridge on US Highway 89. These areas are used for gathering golden eagles and feathers to be used in religious ceremonies. The additional truck traffic along these well-traveled highways would not impair Indian access to the area or affect the current level of religious activity. Arizona Highway Department figures show an average daily traffic count of 7600 [in 1984] and 3100 vehicles along US 89 and US 160, respectively. An additional 20 trucks/day would be virtually unnoticed.


Other sites have been identified in the area including Blue Springs and the Sipapu and Salt Trails. These areas will not be affected by mine operations or ore transport. Finally, in comments regarding other proposed actions on the Kaibab National Forest, the Hopi Tribe has expressed a belief that the earth is sacred and that it should not be subjected to digging, tearing, or commercial exploitation. While this conflict has not been raised directly in relation to the Canyon Mine, it is acknowledged that commercial use of the Forest within the area of Hopi ancestral occupancy is inconsistent with these stated religious beliefs.

Finally, the Canyon Mine EIS (p. 4.44) had this to say with regard to the cumulative impacts of uranium mining in Coconino County on Indian religious concerns:

Indian religious sites and practices are sensitive to increased mineral and industrial activity and thus may be adversely affected by additional mines or other activities that intrude upon land utilized by the Indians. The precise impacts of additional mines, if any, can only be determined on a site specific basis following consultation with the affected Tribes. Tribal leaders must be consulted and included in the decision making process for any proposed mine. Sites of religious significance to the Indians must be identified and avoided or mitigated. However, the Forest Service is not required to protect Tribal religious practices to the exclusion of all other land uses.82 Because of the nature of Indian beliefs and the religious importance of all lands of Hopi ancestral occupancy in northern Arizona any mining activity or ore transport is expected to conflict with stated traditional beliefs that the earth is sacred and not to be developed and is believed by the Hopi to diminish the availability of the land for sacred and religious purposes. This is true of the hunting and gathering activities of the Hopi in the Tusayan area. While each additional mine will only marginally affect these occasional religious uses, the loss of any land is considered significant by the Hopi and each new activity impacts the general environmental setting of such areas and detracts [according to this Tribe] from their religious significance.

82 This freedom of action of the Forest Service to approve coincident other uses of lands being employed for occasional Tribal religious practices was confirmed by the 9th Circuit Court on 8/8/08. See http://www.ca9.uscourts.gov/datastore/opinions/2008/08/07/0615371.pdf . As of January 2009, the Tribes were seeking to appeal this decision in the US Supreme Court (http://www.supremecourtus.gov/docket/08-846.htm.)


Chapter 5. Distribution and Draft EA Preparation

Draft EA Distribution List

The parties listed below received direct notice of the Internet address (http://public.dirxploration.fastmail.us/) where this Draft Environmental Assessment is available for download, along with notice that comments regarding the EA should be forwarded to the NEPA Coordinator for the Kaibab National Forest. The Coordinator concerned is: Mr. Alvin Brown, Forest NEPA Coordinator Kaibab National Forest 800 S. 6th Street Williams, AZ 86046 Email: [email protected] (928) 635-8200 Abajo Archeology

Alpine Archeology

Archeological Consulting Services, Inc.

Arizona Business Gazette

Arizona Business Journal of Phoenix

Arizona Capitol Times (Phoenix)

Arizona Chamber of Commerce and Industry

Arizona Commission of Indian Affairs

Arizona Conservation Partnership

Arizona Cooperative Fish and Wildlife Research Unit

Arizona Daily Star

Arizona Daily Sun

Arizona Department of Commerce

Arizona Department of Economic Security

Arizona Department of Environmental Quality

Arizona Department of Game and Fish

Arizona Department of Health Services

Arizona Department of Mines and Mineral Resources

Arizona Department of Public Safety

Arizona Department of Revenue

Arizona Department of Transportation

Arizona Department of Water Resources

Arizona Game and Fish Department

Arizona Geological Survey

Arizona Governor's Office

Arizona Joint Legislative Budget Committee

Arizona Mining Association

Arizona Office of Tourism

Arizona Power Authority

Arizona Radiation Regulatory Agency


Arizona Republic

Arizona Secretary of Sate

Arizona Silver Belt

Arizona Small Miners Association

Arizona Speaker of the House

Arizona State Land Department

Arizona State Mine Inspector

Arizona State Representatives

Arizona State Senators

Arizona US Representatives

Arizona US Senators

Barbie Drilling

Bureau of Indian Affairs, Arizona State Office

Bureau of Land Management, Arizona Strip

Bureau of Land Management,Phoenix

Bureau of Reclamation

Burlington Northern Santa Fe Corporation

Business Journal of Phoenix

Carothers Environmental Serivces

Casa Grande Dispatch

Chino Valley Review

Citizens' Alliance for Responsible Energy

City Council of Flagstaff

Coconino County Board of Supervisors

Coconino County Sheriff's Department

Coconino Sportsmen

College Times

Colorado River Board of California

Colorado River Commission of Nevada

Colorado River Energy Distribution Association

Colorado Water Conservation Board

Council of Energy Resource Tribes

Council on Environmental Quality

CSM Department of Mineral Economics

Denison Mines

DOE, EIA

Dr. Karen Wenrich

Dr. Michael Folsom

Dr. Mohammed Ikramuddin

Dr. Paul Bailly

Dr. Peter Huntoon

Dr. Phil Geib

Dr. Rod Parnell, NAU geology department

Dr.Richard Foust

Eastern Arizona Courier

EcoPlan Associates, Inc.

Ecosystem Management, Inc.

Energy Fuels Resources, Inc.

Environmental Defense Fund, New York

Environmental Working Group, DC

Envirosystems Management, Inc.


Federation of Fly Fishers Northern Arizona

Flagstaff Chamber of Commerce

Flagstaff Live

Friends of the River

Gateway To Sedona Magazine

Glen Canyon National Recreation Area

Golden Eagle Minerals Ltd.

Governor's Council on Innovation and Technology

Grand Canyon School District

Grand Canyon Association

Grand Canyon Chamber of Commerce

Grand Canyon National Park

Grand Canyon News

Grand Canyon Railway

Grand Canyon River Guides

Grand Canyon School Board

Grand Canyon Trust

Grand Canyon Wildlands Council

Harris Environmental Group,Inc.

Havasupai Tribal Council

Headwaters Economics

Heritage Foundation, Washington, DC

High Country News

Hopi Tribal Council

Hopi Tribe Cultural Preservation Office

Hualapai Tribal Council

Hualapai Tribe, Natural Resources

Humintech GmbH

Indian Country Today

Industrial Commission of Arizona

Jewish News of Greater Phoenix Magazine

Kaibab Band of Pauite Indians

Kane County Commissioners

KNAU

Las Vegas Sun

Liberty Star Uranium

Los Angeles Times

Lumberjack

Mesa Verde Resources

Mohave County Board of Supervisors

Montgomery & Associates

Mountain States Legal Defense Foundation

National Mining Association

Natural Resources Defense Council, San Francisco

Nature Conservancy, Arizona Field Office

NAU Anthropolgy Laboratory

NAU Bilby Research Center

NAU Bureau of Business and Economic Research

NAU College of Business

NAU College of Engineering, Forestry, and Natural Sciences

NAU Forestry Department,


NAU geology department, Abe Springer

Navajo Hopi Observer

Navajo Nation Department of Mines and Mineral Resources

Navajo Nation Tribe

Navajo Times

Neutron Energy, Inc.

New Mexico Interstate Stream Commission

News from Indian Country Today

Northern Arizona Association of Realtors

Northern Arizona Audubon Society

Northern Arizona Council of Governments

Northern Arizona Loggers Association

Northwest Miners Association

Paleowest Solutions in Archeology, Inc.

Pascua Yaqui Tribal Council

Payson Roundup

Phoenix New Times

Prescott Daily Courier

Pueblo of Zuni

Roger Smith

Ron Arnold

Salt Lake Tribune

Sedona Journal of Emergence Magazine

Sedona Red Rock News

Shomaker

Sierra Club -- Grand Canyon Chapter

Sierra Club -- Southwest Office

Southwest Center for Biological Diversity

Southwest Research and Information Center

Superior Sun

SWCA, Flagstaff

Tohono O'odham Nation

Town of Fredonia

Town of Kanab

Town of Williams, Mayor's Office

Tucson Citizen

UA Department of Agriculture and Resource Economics

Upper Colorado River Commission

US Army Corp of Engineers, Headquarters

US Army Corp of Engineers, Los Angeles

US Army Corp of Engineers, Phoenix

US Attorney's Office, Flagstaff

US Bureau of Land Management, Arizona State Office

US Bureau of Land Management, Arizona Strip Office

US Environmental Protection Agency, Region 9

US Fish and Wildlife Service, Phoenix

US Geological Survey

US Geological Survey, Arizona Water Science Center

US Geological Survey, Office of the Director

US Geological Survey, Regional Director

US Geological Survey, Western Regional Director


US House of Representatives, Subcommittee on Environment, Energy and Natural Resources

USDA Forest Service, Kaibab National Forest Supervisor's Office

USDA Forest Service, Regional Forester's Office

USDA Forest Service, Tusayan Ranger District

USDA Forest Service, Washington, DC

USDA Natural Resources Conservation Service, Phoenix

USDA Office of Civil Rights, Washington, DC

USDA Soil Conservation Service, Flagstaff

Utah Asscoiated Municipal Power Systems

Utah Department of Transportation

Utah Divison of Water Resources

VANE Minerals, Inc.

Verde Independent

W. Liebfried Environmental Services

Western Area Power Administration

White Mountain Independent

Wilderness Society, Washington, DC

Williams News

Williams Unified School District

Williams-Grand Canyon Chamber of Commerce

Winslow Mail

Zonge Engineering and Research


List of Preparers

The following people directly prepared of this Draft Environmental Assessment. In contrast, the professional contributions from Paleowest Solutions in Archeology, Inc., and W. Liebfried Environmental Services were cut-and-pastes of the technical reports each business filed on the behalf of DIR Exploration, Inc. and the Kaibab JV with the Kaibab National Forest. Please note that any errors made in the transposition of the work

of the two consultant firms into this Draft Environmental Assessment are those of DIR

and the Kaibab JV, and not those of these two contractors.

Lead Preparer, Consultant to DIR Exploration, Inc.: Mr. Terry W. Fox

Trained as a geologist (University of Utah, BS 1975) and geological engineer, Mr. Fox is certified professional geologist (CPG-8841) and has been an employee of the State of North Carolina since 1990, starting work as a project and senior project engineer for the State’s Low-Level Waste Management Authority. Duties as a Senior Project Engineer included monitoring and managing complex and controversial site characterization activities for the Southeast Compact Radioactive Waste Facility (“SECRWF”) in North Carolina. Fieldwork was conducted by private geo-environmental and geotechnical consulting firms, covering 21 disciplines including geology, environmental, hydrogeology, mineral resources, and archaeology, at two sites in NC for the preparation of a license application for a low-level radioactive waste disposal facility. Mr. Fox managed the summation of field data into, and consultant preparation of, the Draft EIS and Final EIS documents associated with the SECRWF, conducted scoping meetings for both regulators and the public for review and comment, and served as advisor on geological matters to the Waste Management Authority, NC Dept of Justice attorneys, State regulatory personnel, and other agencies. Beginning in 2006, Mr. Fox became GeoEnvironmental Project Manager for the North Carolina Department of Transportation. There he oversees the scope and schedule of all Phase 1 environmental assessments, Phase 2 investigations, and Phase 3 hazardous materials remediation activities for Federal Interstate, State highway projects, Federal military installations, airports, railroads, ferry terminals, pedestrian, and bicycle trails, NPS Recreation Areas, and other State and Federally owned properties throughout North Carolina. In this capacity, Mr. Fox coordinates with private environmental consultants under contract with the NCDOT and parties within the NCDOT to ensure that the projects meet transportation needs and schedules. His duties also include the performance of geotechnical, geological and hazardous waste site characterization activities to assist other state agencies in the preparation of EA and EIS documents, the review of consultant reports, and the composition and submission of final environmental assessment reports for submission to affected parties. Mr. Fox is very familiar with northern Arizona uranium-mineralized collapse breccia pipe geology, exploration, mining, and milling, having worked for Energy Fuels Nuclear, Inc., from 1978 through 1986, in its milling, mining, and exploration departments.


Second Preparer, DIR Exploration, Inc. Managing Geologist: L. D. Turner

Mr. Turner is a geologist (BS, Eastern Washington State College, 1975), geochemist (MS, Eastern Washington University, 1981), and mineral economist (MS, Colorado School of Mines, 2000). Mr. Turner has worked in mineral exploration geology for 34 years, and began conducting uranium exploration in northern Arizona in 1981. A co-founder of DIR, he managed all breccia pipe exploration operations on the Tusayan Ranger District for DIR and DIR’s Joint Venture partner, PNC Exploration (USA), Inc., from 1987 through 1993. Mr. Turner’s MS study in geochemistry also included training in soil science, biology, and biogeography. Emphasis of his graduate geochemical training was surface and near-surface geochemistry of metals, especially the behavior of uranium in surface and ground water. His MS geochemical thesis examined the chemical relationship between dissolved organic matter and metals in the streams of the Republic area of northeastern Washington. His recent minerals economics work at Golden, Colorado, included study of qualitative and quantitative economics, risk- and decision-analysis, and econometrics, and concluded with completion of a thesis based on an econometric examination of the US copper and iron mining industries. This examination concluded that both industries were already economically suffering from ore depletion and that neither industry was prepared for declining petroleum production.

Editor and reviewer, DIR Exploration, Inc. VP: I.L. Turner

I.L. Turner is a mining and mineral exploration geologist with more than 50 years experience in the minerals industry. He earned his BA in geology/physics at Southern Illinois University in 1958, and his MS in geology at the University of Tennessee in 1960. First employment was with the St. Joseph Lead Company as mine geologist, then district geologist and exploration geologist in the southeastern Missouri lead belt. During 1969 to 1973, this Mr. Turner worked as district geologist for Vanguard Exploration at the Pend Oreille Mine and in the encompassing Metaline Mining District in northeastern Washington State. From 1973 to the present, he has lived in Colorado, and initially worked from there with NL Industries as special projects geologist with emphasis on the Bayhorse fluorspar-base metal Mining District in Idaho. In 1976 he joined Texasgulf Minerals and Metals Co. as manager of coal and potash exploration, then as manager of North American base metals exploration, and lastly as vice president of exploration. Since 1986, Mr. Turner has worked as a geological consultant, primarily in the Illinois-Kentucky fluorspar/base metal Mining District as well as a partner/VP with DIR Exploration in Arizona and Nevada. Mr. Turner co-founded DIR with L.D. Turner in 1983.


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Appendix – Production Function Estimations

Introduction

In addition to the statistical test results summary of the three production functions shown on page 131 of this report, the following statistical test results of the estimated equations also indicate each equation is suitable for the use of policy-makers. “Ln” = natural log; “EXA” = annual exploration acres; “EXH” = annual exploration drill holes; “DISC” = annual ore body discoveries; “PRICE(-2)” = uranium price two years previous; “PRICE(-3)” = uranium price three years previous; “PRICE(-4)” = uranium price four years previous. Note that the coefficients of these constant elasticity equations are also the elasticities of these coefficients. Value of the elasticity for each variable

measures the percentage change in the dependent variable caused by a one percent

change in the controlling variable concerned.

Equation 1

Ln (EXA) = 7.0481361 – 2.9318118 x Ln [Price(-2)] + 2.1876778 x Ln [Price(-3)]


Equation 2

Ln (EXH) = 4.8416679 – 2.5857622 x Ln [Price(-2)] + 2.6021975 x Ln [Price(-3)]


Equation 3

Ln (DISC) = -2.118777 – 1.7873386 x Ln [Price(-4)] + 2.5030242 x Ln [Price(-3)]

Dir Draft Ea 2-13-09

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