$3,939 $4,409 $7,908 Notes: Capital costs are annualized as follows:  Current Practice capital costs are annualized at 7% over 15 years, reflecting assumption that operations at a site would last at most 15 years. Geochemical capital costs are annualized at 7% over 20 years, consistent with expected life of capital equipment. 30-year capital costs are annualized at 7% over 20 years, with an assumed 10% of wells requiring replacement after 20 years. Incremental total annualized costs subtract the estimated annualized monitoring and capital costs for each regulatory scenario minus the estimated annualized monitoring and capital costs under current practice.

3.3	Estimated National Costs of Proposed Rule The final step in estimating the costs of the rule and evaluating how they compare with the costs of current practice requires extrapolating from the costs estimated for the CMU to estimated costs that apply to ISR facilities projected to exist in 2014. As mentioned in Section 2, above, six ISR facilities currently operate: La Palangana, Alta Mesa, Willow Creek (Christensen and Irigaray), Crow Butte, Lost Creek, and Smith Ranch-Highland-Reynolds. Several other ISR facilities are in various stages of licensing and are not in operation. The cast of ISR facilities in operation can be expected to vary over time, depending on uranium market conditions and how long it takes to extract the uranium from deposits at each facility. EPA has chosen to use the existing ISR operations in 2013 and the companies that own them as models for ISR facilities and owner companies likely to exist in the future and thus be affected by the proposed rule. EPA had some information about existing ISR facilities, but not sufficient information to estimate their costs on a facility-specific or wellfield-specific basis. Thus, it was necessary to extrapolate or scale up the costs estimated for the CMU to estimate costs that would be incurred by existing ISR facilities. EPA examined three possible bases on which to extrapolate the CMU costs to estimate the costs that would be incurred at ISR facilities: facility capacity uranium production wellfield acreage After considering these options, as described below, EPA determined that extrapolation based on wellfield acreage is the most reasonable basis. Facility capacity is reported by the EIA in its Uranium Production Report, so it is available for all planned and actual ISR facilities. However, facility capacity is measured in terms of the production capacity of the processing plant. Although this may be correlated to the size and complexity of the wellfield, and thus to the capital and operating costs of monitoring, the link is not close and would not seem to provide a reliable method of scaling site-specific costs to nationwide estimates. Uranium production at a particular facility may vary widely from year to year because of changing conditions in the uranium market or facility-specific factors. We do not, however, expect monitoring requirements or costs to vary significantly from year to year, although we recognize that they vary depending on the phase of the ISR operation. Some correlation can generally be assumed between the size of the wellfield and the numbers of wells required for monitoring and, therefore, between the size of the wellfield and the corresponding well and groundwater sampling costs. Thus, EPA chose to use wellfield acreage as the basis on which to scale up costs from the CMU to the facility level. EPA obtained maps of wellfields or used available published information for the five existing ISR facilities to estimate the acreage of each wellfield. There is a large variation in the size of existing wellfields based on the information available from a variety of sources. Individual wellfield size for the sites considered ranges between approximately 7 acres and 750 acres. The total acreage of all the individual wellfields at each of the ISR sites considered is shown in Table 3-7.  The costs that would be incurred by each ISR facility under current practice and under each regulatory alternative were estimated based on the ratio of the ISR facility's total wellfield acreage to that of the CMU (see Table 3-7). Table 3-7.	Estimated Total Acreage of All Wellfields at ISR Sites ISR Operation Acres La Palangana[a] 210 Alta Mesa 330 Willow Creek 409 Crow Butte 1,524 Smith Ranch-Highlands-Reynolds 6,582 Lost Creek 254 Conceptual model unit 202 a 	Palangana total acreage scaled up by 50% to estimate area including PAA3. Note: Most site acreages computed using site map and planimeter. Table 3-8 shows estimated costs for each of the ISR facilities, based on the total acreage of the wellfield at each facility. EPA recognizes that not all the wellfields at all facilities may be in the same phase of uranium recovery at a given time; some may be in a planning stage, others actively being mined, while others are undergoing restoration and still others may be decommissioned. To evaluate potential impacts based on a conservatively high range of costs, we estimated costs using 100% of wellfield acreage at each facility to analyze the economic impacts of the proposed rule; generally, this overstates annual costs. An uncertainty in this approach relates to the potential for ISR sites to contain multiple ore zones within the same surface area (i.e., ore bodies located at different depths and separated by isolating beds), thereby allowing sequential uranium recovery within the same surface footprint. In that situation, acreage  Table 3-8.	Total Average Annualized Incremental Costs for Individual ISR Operations (Thousand 2011$) Regulatory Scenario 30 year, Geochemical Modeling to Shorten 30 Years, No Shortening Geochemical Modeling, Extended Cost per acre $1.45 $1.62 $1.86 ISR operation

La Palangana $304 $340 $390 Alta Mesa $477 $534 $613 Willow Creek $591 $661 $759 Crow Butte $2,205 $2,468 $2,832 Smith Ranch-Highland-Reynolds $9,521 $10,657 $12,229 Lost Creek $367 $411 $472 National Cost $13,465 $15,072 $17,296

would not be as closely correlated with costs of complying with the rule. Facility-level incremental total annualized costs are estimated to range from $304,000 to $9.52 million under the proposed rule (30-year with geochemical shortening option), and from $340,000 to $10.7 million under the required 30-year monitoring option, when costs are calculated based on the entire wellfield acreage. Facility-level incremental total annualized costs were also estimated for the worst case scenario, under the proposed regulatory approach, to be from $390,000 to $12.2 million with the failure of geochemical modeling to predict a stabilized condition in the wellfield then requiring 30-years of long-term monitoring. National costs computed using this assumption are $13.5 million for the proposed rule, 30 years with geochemical modeling, and $15.1 million under the 30-year long-term stability monitoring alternative. Under the scenario where geochemical modeling is followed by 30 years of long-term stability monitoring, average national total annualized costs are estimated to be $17.3 million. The well costs and the duration and frequency of sampling assumed for costing these scenarios are different. The geochemical scenario incorporates additional well and boring costs and assumes fewer years of sampling are needed. The frequency of sampling is consistent between the scenarios considered but the geochemical modeling scenario accounts for additional constituents that will need to be sampled and monitored. Labor and other routine costs were held constant between the scenarios considered. Table 3-9 presents summary values for national-level costs, including annualized, summed, and discounted present value of costs. Finally, national well development capital costs are presented in Table 3-10. The well development costs for geochemical modeling with required 30-year monitoring are based on the well development costs for geochemical modeling. Table 3-9.	Estimated Average National Incremental Cost Summary (Thousand 2011$) Regulatory Scenario 30 Year, Geochemical Modeling to Shorten 30 Years Geochemical Modeling, Extended Total annualized cost $13,465 $15,072 $17,296 Total cost, summed across LOM $431,284 $814,903 $854,177 Present value, 3% discount rate  $289,991 $419,826 $456,257 Present value, 7% discount rate  $181,135 $202,754 $232,673 Scaled up from CMU costs to national costs based on estimated total acreage. LOM is life of mine. Table 3-10.	Incremental Total Capital Costs (Thousand 2011$)

Cost, $ 30 years with geochemical modeling $25,203 30 years long-term stability monitoring  $19,339 Scaled up from CMU costs to national costs based on estimated total acreage. 3.4	Uncertainties and Limitations EPA illustrated three regulatory alternatives using a CMU. As part of this exercise, we assumed the duration of each phase of the ISR monitoring operation. These durations are reasonable, but arbitrary assumptions. All could be longer, and all except the 30-year post-monitoring schedule under those regulatory alternatives could be shorter. A major set of uncertainties arises from the process used to extrapolate from the estimated costs of each regulatory alternative at the CMU to costs that would be incurred by other ISR facilities. Due to limited resources and data accessibility, EPA's cost estimates are based on a model facility approach, with the model derived from the characteristics of a single wellfield at one ISR facility. Additional data collection could help to refine these cost estimates; however, despite these limitations we believe that the cost estimates presented here would generally approximate those for mine units characteristic of other ISR sites. EPA also recognizes that compliance actions required at a particular site depend on the characteristics of the site; the characteristics of the CMU may not closely correspond to characteristics of other existing or new ISR facilities. Thus, the costs actual ISR facilities incur may differ from the costs described here. Further, EPA is using existing ISR facilities as models for future ISR facilities that may be subject to the proposed rule at different times in the future. Although future ISR facilities may differ in various ways from existing ISR facilities, EPA nevertheless believes that the existing facilities provide the best guide available as to what future ISR facilities may be like. Another uncertainty is the cost savings a facility may experience if it applies for and receives an ACL. EPA recognizes that ISR facilities that are attempting to restore and stabilize an ISR site may determine that they are unable to return contaminant concentration levels for all constituents to baseline/pre-operational levels as required. In that situation, facilities may apply for an alternative concentration limit for those constituents. Receiving approval of ACLs would likely enable the facility to stop its restoration/stabilization activities, rather than continuing efforts to achieve pre-operational levels of all constituents. This arrangement would likely reduce the number of years over which the site would have to be monitored. Obtaining an ACL would also entail some additional effort and cost associated with negotiating the ACL with the licensing agency. As an example of such costs, if a constituent (e.g., radium or a trace metal) remains above the restoration goal, the owner/operator may make an argument that the adverse health effects of the higher concentration level are not significant. In that example, a dose assessment would be part of the operator's case to obtain an ACL and such an assessment would entail costs to gather data and perform the assessment. EPA does not have enough information to enable it to estimate the cost savings associated with ACLs, but we do recognize that there could be cost savings, relative to extensive efforts to achieve pre-operational levels for all constituents. Requirements for licensing are described in 10 CFR Part 171.16, and financial assurance requirements for ISR operations are described in 10 CFR Part 40, Appendix A, Criterion 9. EPA's proposed rule will not change the substance of the requirements affecting ISR facilities, but it will potentially change the duration over which a facility is subject to the requirements and thus incurs the costs. Because both types of requirements are set for the entire facility (although they vary depending on the activities currently under way at a facility), as long as any activity is under way at a facility, the facility will incur the costs of complying with the requirements. License fees range from $35,400 to $40,000 per year, but drop to zero if only decommissioning is occurring. Financial assurance costs continue through decommissioning, but decline as more of the site is decommissioned. Throughout the life of an ISR operation, the costs associated with licensing and financial assurance would, in EPA's assessment, be unaffected by the proposed rule, until only one wellfield is still in operation or undergoing decommissioning. . The longer duration of monitoring required would cause the firms to incur the costs associated with financial assurance for a longer period of time (potentially 30 years). However, as the number of wellfields in operation declines, and the amount of radioactive material onsite declines, the magnitude of the financial assurance required would decline proportionally. EPA thus believes that the additional costs associated with payment of license fees and financial assurance would be small relative to other incremental costs and thus we did not include them in our quantitative estimate of costs and impacts.

      Benefits Analysis The benefits from revising Part 192 will primarily result from measures to prevent future occurrences of groundwater contamination and protection of groundwater resources for future generations. By requiring owners and operators of ISR facilities to take actions that ensure the long-term stability of geochemical conditions in on-site and nearby aquifers, the revisions will (1) help preserve the quality and quantity of increasingly scarce groundwater resources in the U.S., (2) reduce potential human and environmental health risks associated with contaminant exposures, and (3) avoid potential future remediation costs, which would be required if the existence and migration of groundwater contaminants were not detected prior to decommissioning the site. In addition, by incorporating constituent-specific standards that are flexibly referenced to SDWA and RCRA standards for groundwater contaminants, the proposed revisions will reduce the Agency's administrative burden from periodically reviewing and revising standards to ensure consistency. In so doing, they will also incorporate recently revised and more protective standards for arsenic and uranium, which will also contribute to reduced risks to human health and the environment. Due to data limitations and resource constraints the monetary value of these benefits cannot be fully quantified and aggregated across ISR sites in the U.S. However, it is possible to provide a detailed qualitative discussion and partially quantified description of the expected benefits of the proposed rule. The purpose of this chapter is to assist decision makers by providing this discussion and description of benefits. 4.1	Conceptual Framework and Methods for Valuing Groundwater Resources and Groundwater Protection Water is vital to a productive and growing economy in the United States, directly and indirectly affecting the production of goods and services in many sectors. Current economic literature provides many insights into the importance of water to various sectors, including agriculture, tourism, fishing, manufacturing, and energy production, but this information is dispersed and, in many cases, incomplete. To take stock of what is currently known and where the main knowledge gaps lie, EPA has been conducting a study on the importance of water in the U.S. economy (U.S. EPA, 2012d). The main objectives of the study include (1) summarizing existing knowledge about the role and importance of water to the U.S. economy; (2) providing information that supports private and public sector decision-making, and (3) identifying areas with additional research needed. The draft findings show that, although water plays an essential and vital role in the economy, it is enormously difficult to place a monetary value on its contribution, in part because the value of water varies greatly both within and across sectors of the economy. Although groundwater resources play a vital role in the U.S. economy, the economic value of these resources extends beyond their current contribution to market production. To understand and fully account for the contributions of groundwater to human well-being is useful to refer to the concept of "total economic value" (TEV) (Young, 2005). As shown in Figure 4-1, TEV includes both use and nonuse values. Figure 4-1.	Main Components of the Total Economic Value (TEV) of Groundwater Resources

Use values include the well-being that is derived from direct use of the resource by individuals or households, for example as a source of drinking water. It also includes values from indirect use, such as through groundwater's contribution to the production of goods or services people enjoy (e.g., agricultural commodities). As noted in a 1997 National Academy of Sciences study of groundwater valuation (NAS, 1997), use values for groundwater can also be divided into extraction value and in-situ value (also described as consumptive vs. nonconsumptive use values). Extraction value is widely recognized, and includes the value of groundwater used for drinking water, industrial water supply, and agriculture. Values for in-situ services are (or were in 1997) less well-known. They represent services or values that occur or exist as a consequence of water remaining in place within the aquifer. They include the capacity of groundwater to (1) buffer against periodic shortages in surface water supplies; (2) prevent or minimize subsidence of the land surface from groundwater withdrawals; (3) protect against sea water intrusion; (4) protect water quality by maintaining the capacity to dilute and assimilate groundwater contaminants; (5) facilitate habitat and ecological diversity; and (6) provide discharge to support recreational activities. One potential additional source of use values is "option value," which refers to the value that humans derive today from preserving the option to use the resource (directly or indirectly) in the future. Nonuse values refer to well-being derived from the resource that is not associated with an individual's current or future use of the resource. Two main types of nonuse values are (1) the "existence" value that individuals may derive simply from knowing that a resource exists and is being protected, even if they do not or have no intention to use the resource directly or indirectly and (2) the "be	quest" value individuals derive from know that a resource is being preserved for future generations to use. One of the main challenges with valuing groundwater resources and their services is that they are typically not privately owned or exchanged in markets. As a result, one cannot rely on market prices for groundwater to infer its values. To address this problem, which is common for many public goods and natural resources, economists have developed variety of nonmarket valuation method. These methods are typically divided into two main categories: revealed and stated preference methods. To infer nonmarket use values, revealed preference (RP) methods rely on information from market activities or other human behaviors that are related to the resource of interest. For example, the value of groundwater as an irrigation resource can be inferred from the value it contributes to products sold in agricultural markets. Similarly, the value of protecting groundwater quality as a source of household drinking water may be inferred from substitute sources of drinking water (e.g., bottled water prices) or from differences in housing prices in areas with different groundwater quality. Unfortunately, RP methods cannot be used to estimate nonuse values for natural resources, because they require a behavioral connection to the resource of interest in order to infer values. The value of protecting groundwater quality may also, in some cases, be inferred from the avoided future costs of restoring the resource. This approach, which is sometimes grouped with RP methods, is meaningful if there is a high likelihood that (1) restoration activities will be implemented if groundwater contamination occurs and (2) restoration activities will not be needed if the groundwater is protected. Stated preference (SP) methods employ household surveys to more directly measure people's nonmarket values. To address the lack of existing markets for the good or service of interest, SP surveys present respondents with hypothetical markets or scenarios and elicit their willingness to pay (WTP) for defined changes (e.g., improvement in groundwater quality). One of the main advantages of SP methods is that they allow researchers to specifically define the nonmarket "commodity" of interest. Moreover, unlike RP methods, they can be used to capture and estimate nonuse value. The main drawback of these methods is that it is difficult to validate WTP estimates based on responses to hypothetical conditions. A number of studies have used SP methods to estimate U.S. households' WTP for protecting and improving groundwater quality; however, most of these studies were conducted in the 1980's and 1990's. Using meta-analysis, Poe et al. (2001) reviewed and synthesized key findings from this empirical literature. In particular, they identified and analyzed 105 WTP estimates from 12 studies. They found that the types of groundwater changes described and analyzed in these SP studies varied widely, and consequently the mean annual WTP estimates also varied significantly from $46 to $1,316 (in 1997 dollars). Using a consumer price index adjustment, this range is equivalent to $64 to $1,844 in 2011 dollars. Poe et al. used regression methods to investigate the main determinants of this variation in WTP. For example, they differentiated between studies that focused mainly on use-related values associated with drinking water protection and those that used a broader environmental perspective and included nonuse values related to aquifer protection. They found that including a nonuse perspective had a significantly positive effect on WTP. They also differentiated studies that specifically mentioned cancer risks associated with groundwater contamination. They found that WTP estimates were higher in these studies, but only at a moderate level of statistical significance. 4.2	The Benefits of Proposed Changes in Monitoring Requirements The purpose of the proposed change in monitoring requirements, including requiring improved characterization of groundwater prior to uranium recovery and more extensive restoration and post-restoration stability monitoring, is to reduce the probability and magnitude of potential groundwater contamination incidents resulting from ISR operations. Currently NRC allows ISR operators to terminate their license at the end of a relatively short (one to two years) stability monitoring phase. However, this practice means that any later contamination might not be detected and corrected in a timely manner. If oversight at these facilities ends before groundwater conditions have in fact stabilized, there is the potential for ongoing contamination. Thus, the proposed rule's provisions help to ensure that any potential excursions occurring after the completion of production operations are detected and corrected. As a result, they would ensure that groundwater and, potentially, the surface water to which it discharges, remain at levels the groundwater was restored to. Stability period monitoring ensures that the long-term trends in the groundwater concentrations stay within the target restoration concentrations ensuring the stability of the aquifer water quality and class of use required by regulatory authorities (Davis, 2007). This monitoring reduces the probability of water quality degradation within the exempted aquifer, prevents further degradation of the overlying or underlying aquifer, and reduces the probability of aquifer degradation outside the ore zone. By ensuring that groundwater conditions within the exempted aquifer are in fact stable, the proposed stability monitoring program will reduce the likelihood of undetected degradation of conditions in the exempted aquifer and adjacent aquifers. Thus, the proposed stability monitoring program would result in a higher probability that adverse human health and environmental impacts will be avoided. There are several potential benefits associated with preventing groundwater contamination due to post-restoration exceedances/excursions at ISR facilities. The following discussion describes three main areas and offers insights into the potential magnitude of these benefits. 4.2.1	Reducing Potential Human Health Risks Associated with Contaminant Exposures If excursions occur from ISR facilities and aquifers are contaminated, the main potential risks for human health would be those associated with exposures to radionuclides in well water used for drinking or agriculture in areas located down-gradient from an ISR site. Most importantly, EPA considers all radionuclides to be known (category A) human carcinogens, and exposures to radiation can cause cancers in almost all tissues and organs in humans. To evaluate the potential human health risks that would occur if groundwater contamination were to result from ISR operations, EPA evaluated a number of exposure scenarios and pathways (U.S. EPA, 2012c). The findings of this analysis indicate that the migration of contaminants into aquifers in the vicinity of an ISR site has the potential to cause significant exposures and risks for selected receptors. For example, the maximum of the estimated adult cancer risks from these scenarios was an increased latent cancer fatality risk of almost 5 in 1000 per year of exposure. However, due to the slowness of the groundwater transport process, it could take several decades or more for the contaminants to reach down-gradient wells that could potentially be used by humans. Also, the exposure scenarios examined in the analysis deal with failures of the ISR operations during the operating phase, such as leaks from extraction wells into overlying potable water aquifers or surface spills during operations. These scenarios can pose exposure risks, but implementing a robust regulatory regime during operations (the responsibility of the NRC or Agreement States) would minimize the potential for significant exposures. Estimating the monetary value of health benefits from the proposed rule requires estimates of the expected number of cancer cases and fatalities that would be avoided. To estimate the benefits of avoided mortality risks from its programs and policies, EPA recommends multiplying the number of avoided deaths by a "value of statistical life" (VSL) concept, with a central default estimate of $8 million per avoided premature death. This VSL estimate is based on a review and synthesis of findings from several empirical nonmarket valuation studies, which estimate individuals' WTP to reduce their own probability of premature death. Unfortunately, due to uncertainties and data limitations, including lack of certainty regarding the size of future populations in proximity to ISR operations, it is not possible to estimate these population-level risk changes for this rule; however, the VSL of $8 million at least provides a point of reference for understanding the potential value of health benefits of the proposed rule. It is also worth noting that the unit value for avoided cancer fatalities may be even higher than the $8 million VSL. Economic studies of VSL suggest that people value reductions in cancer risks by more than similar reductions in noncancer risks of mortality, because individuals fear the pain and other symptoms associated with cancer more than they fear, for example, traffic or work-related accidental death (U.S. EPA, 2010). Moreover, as previously described, the findings from the Poe et al. (2001) meta-analysis of groundwater valuation studies suggest that individuals place a particularly high value on avoiding groundwater contamination when cancer risks are involved. 4.2.2	Protecting Groundwater Resources for Future Generations As described above, groundwater resources provide a wide variety of extractive, in-situ uses, and nonuse values and services to human populations in the U.S.; however, the ability to sustain these services over the long term is being threatened by groundwater scarcity. Due to population growth and technological advances, the pace of groundwater extraction in the U.S. has increased significantly in the last 75 years (Reilly et al, 2008). As a result, declining groundwater resources are a growing concern in many parts of the country. Continuing population growth and the additional threats to water resources posed by climate change only serve to reinforce these concerns. Growing scarcity also means that existing groundwater stocks are becoming increasingly valuable. Therefore, even though the aquifers in the vicinity of ISR operations are currently providing relatively little extractive value (due to their locations in relatively sparsely populated areas), there are potentially significant longer term benefits to protecting these resources for future generations. The fact that ISR operations are mostly located in arid regions of the country where water scarcity is a chronic problem further underscores the significance of these benefits. Empirical evidence regarding these "bequest" values for protecting groundwater resources is limited; however, the Poe et al. (2001) meta-analysis provides some insights into the magnitude of these nonuse values. In particular, valuation studies that focused broadly on aquifer protection, rather than more specifically on use values associated with drinking water protection, had average WTP estimates that were larger by $531-$736 per household. 4.2.3	Avoiding Potential Future Remediation Costs Under current conditions, due to limited post-restoration monitoring by ISR operations, the potential exists for groundwater contamination to occur and go undetected over a long period of time. Such processes could occur if the initial injection of oxidizing agents into the deposit also destroyed the natural reducing capacity in the host rock that immobilized the uranium initially. Later injection of chemical reducing agents may then only produce a temporary reduction of uranium mobilized by the lixiviant injection. Over time the influx of oxidized groundwater from up gradient of the deposit may remobilize the uranium, radium, or other constituents, and result in contaminant migration down gradient. If such contamination does occur and is only discovered after a long delay, extensive and costly remediation would most likely be required to remove the contaminants from the aquifer and reduce human health and environmental risks to acceptable levels. As the time period before detection increases, it is also likely that the spatial extent of contamination and the corresponding remediation costs would increase. A long delay before detection could also decrease the likelihood that the ISR owners/operators will be held responsible for the cleanup costs and instead the burden could be shifted to future taxpayers. Consequently, one of the expected benefits of the proposed rule will be to increase the likelihood of detecting mobilized uranium, radium, or other constituents at an early stage and therefore avoiding costs associated with more extensive remediation activities. To analyze these avoided remediation costs, we used the model facility described in Section 3, and applied the parameters of this facility to develop cost estimates for alternative remediation scenarios. Appendix C provides a detailed description of the methods and assumptions used to construct these remediation cost estimates. Note that this is an illustration of potential costs and cost savings associated with the proposed rule for a model mine unit; because we have no idea of which (if any) wellfields would experience a remobilization after restoration, EPA is unable to estimate national cost savings from reduced remediation costs.  As described in Appendix C, EPA used different assumptions about groundwater flow to estimate distance from the location where the constituents are first mobilized to the nearest monitoring well, and hence how long it would take for contamination to be detected. In addition, a variety of Kd values were used, to reflect a variety of assumptions about how readily constituents are transported in groundwater. For purposes of this discussion, we focus on calculations assuming that Kd = 6.0E-06 m3/gm. The Kd variable is a site specific measurement and limited examples were found for actual ISR sites that were measured either as part of baseline or after restoration was completed. The value selected for modeling purposes was a referenced (F.J. Pearson Jr., C.J. Noronha, and R.W. Andrews, 1983) Kd measured at a roll front sandstone site and was used as a representative general condition. To evaluate the potential magnitude of the benefits associated with avoided remediation cost, we compare two main scenarios. The first scenario represents conditions without the proposed rule. Under this scenario, contamination is detected after the site is decommissioned and the license is terminated. Three situations are examined: a small plume that is approximately 10% of the wellfield, or a larger plume that fills the entire wellfield. Once contamination is detected, this scenario estimates that remediation activities would continue for a period of 30 years (small plume) or 60 to 75 years (larger plume), involving pumping and treatment of contaminated groundwater from approximately 70 wells. For the larger plume, costs and duration vary depending on assumed direction of groundwater flow; we examine two possible directions because the current direction appears to be different from historical direction, possibly because of other mining activities in the area. Estimated total annualized costs of this scenario range from $1.45 million (small plume) to $10.3 to $10.5 million (large plume). Because the site has been decommissioned and the license terminated, remediation costs might be borne by the taxpayer. Total costs, as shown in Table 4-1, range from $35.3 million for a small plume to $586 million for a large plume, where the groundwater flows along the length of the wellfield. The second scenario represents conditions with the proposed rule. In this case, contamination is assumed to be detected during long-term stability monitoring. We use costs for the 30-year with no geochemical modeling alternative, and assume that monitoring within the wellfield detects an increased concentration of constituents ten years into the 30 year period. When the remobilized constituents are detected, the licensing agency would require the owner/operator to resume restoration activities, in an effort to achieve restored, stable conditions. To estimate the costs of this additional restoration, we use the estimated restoration costs for the original restoration phase. We assume that the second restoration would be successful and no further remobilization of constituents is detected. After this second restoration, the facility would monitor to ensure that constituent levels are stable at 95% confidence for 3 years, then continue to monitor to ensure that stability is maintained for 30 years. EPA estimates that the cost of these activities would total $27.1 million. The resulting estimates of avoided remediation costs for the model facility are summarized in Table 4-1. The summary costs for each scenario are expressed as a lump sum value, computed by summing costs across time. The avoided remediation costs are calculated as the difference between the two scenarios. Therefore, for this example facility and post-restoration contamination profile, the estimated benefits from the proposed rule include a value of at least $8.2 million to nearly $560 million in avoided remediation costs, including both capital/well development costs and annual costs.  In addition, the proposed rule is expected to shift the burden of required groundwater cleanups from future taxpayers to the owners and operators of ISR facilities. By requiring ISR operations to conduct more extensive long-term stability monitoring, it is more likely that movement of contaminants will be detected in the short term while owners and operators are still responsible for the site. Conversely, it is less likely that contamination episodes will go undetected for years into the future and be detected only after the facility has been decommissioned, thus reducing the probability of larger and taxpayer funded remediation activities.

Table 4-1.	Summary of Avoided Remediation Cost Estimates for Model Facility with Post-restoration Groundwater Contamination (million 2011 $) Plume Size and Groundwater Flow Direction Sum of Costs Over Time

Without-regulation Scenario (A) With-Regulation: Compliance and Additional Restoration (B) Avoided Remediation Costs (A) − (B) Small Plume $35.3 $27.1 $8.20 Large Plume, Transverse $481.0 $27.1 $453.1 Large Plume, Along $586.1 $27.1 $559.0

Further, the proposed rule, with its geochemical modeling and monitoring components, provides both the regulator and the public with evidence that restored wellfield conditions will remain stable into the future and that the operator can be released from a 30-year long-term stability monitoring requirement and the site decommissioned, with greater confidence in its long-term safety than could be achieved based on monitoring alone. 4.3	Setting Groundwater Protective Standards The second component of the revised regulation aligns the groundwater standards to current regulatory criteria (i.e., primary and secondary maximum contaminant levels (MCLs) under the SDWA and/or maximum concentration of hazardous constituents for groundwater protection under RCRA). The primary benefit to households of revising the standards will be reduced risk of adverse human health and environmental impacts. As proposed, the revisions will reduce the need for EPA to update the regulations each time a standard changes and avoid the rulemaking process for each update, thus reducing future regulatory burden on both EPA and the regulated community. Rather, EPA would take comment during the rulemaking process for the primary rule that is being changed. Currently the list of groundwater standards is out of date and not aligned to SDWA and RCRA. Aligning the standards will ensure that the standards stay current with other regulations and increase the probability that society will be protected from risks to human health and the environmental. The requirement requires that regulators and operators update their plans based on the latest standards, but it relieves EPA of the costs associated with updating the regulation each time a standard is changed and ensures that there are no lags in updating the standards, which would potentially expose the public to risks. 4.4	Comparison of Benefits and Costs of the Proposed Rule Since EPA conducted a qualitative assessment of the benefits of the proposed rule, a direct quantitative comparison of total benefits and costs is not possible. However, the analysis described in this section does provide some limited insights into the relative magnitude of costs and benefits. In particular, for the model facility with a defined excursion of groundwater contamination, the estimated net present value of avoided remediation costs is at least $35.0 million, whereas the NPV of monitoring costs plus a second remediation has an estimated NPV of $11.0 million, based on average costs and using a 3% discount rate. Therefore, for this example, the cost avoidance benefits exceed the costs. Whether this relationship holds at an aggregate level, however, depends importantly on (1) the likelihood of groundwater contamination events across all sites and (2) the similarity of conditions at other sites to those at the model facility. 4.5	Caveats and Uncertainties Although the proposed rule is expected to provide substantial benefits by helping to ensure that potential groundwater contamination occurrences from ISR operations are promptly detected and addressed, it is not possible to reliably quantify the total magnitude of these benefits. One of the main sources of uncertainty is a lack of adequate data and models for estimating a full probability distribution of all alternative groundwater contamination scenarios across all current and future ISR sites. Instead, to provide a general understanding of avoided remediation costs and avoided health risks, EPA has examined a limited number of groundwater contamination scenarios at a defined site to illustrate the magnitude of potential remediation costs. It should not be assumed that all restored ISR wellfields will fail in the long-term. A second important source of uncertainty is for estimating benefits is the very long term nature of potential groundwater contamination episodes. Although future generations will certainly benefit from avoided contamination, it is very difficult to reliably predict the size and locations of potentially affected future populations.

      Economic Impact Analysis EPA examined the economic impacts that may result from the proposed rule, using information about the industry and estimated incremental costs that would result from the proposed rule and from one additional regulatory alternative, and employing accepted economic analysis methods.  5.1	National Costs EPA first estimated the total annualized national cost of the proposed rule, as a measure of the overall impact the proposed rule might have on the uranium industry and the national economy. As described in Section 3, EPA estimated the incremental annual costs of monitoring for ISR facilities; EPA first estimated the costs under current practice and under two regulatory alternatives for a conceptual mine unit (CMU) model facility. Incremental costs were computed by subtracting the estimated base case costs from estimated costs under the two regulatory alternatives. EPA then scaled up the estimated incremental costs for the CMU to costs that would be incurred by facilities such as the five ISR facilities expected to be operating in 2014, the effective date of the proposed rule, based on the ratio of the wellfield acreage at each facility to the wellfield acreage of the CMU. EPA illustrated the range of costs that may result from the proposed rule using average, low, and high costs of monitoring. This approach makes the conservative high-cost assumption that all wellfields at each facility would be in some stage of pre-operations, operations, restoration, stability, or long-term stability monitoring (and thus affected by the proposed rule) in 2015. Estimated national total annualized costs based on average monitoring costs are shown in Table 3-9, above, and used in this analysis. National costs based on low and high monitoring costs are shown in Appendix D. Depending on the assumptions used to compute the national costs, EPA's cost estimates varied widely, ranging from $11.6 million to more than $17.9 million. EPA examined the potential costs of the provisions of the proposed rule (30-year stability monitoring with the potential to reduce the duration if geochemical modeling demonstrated that wellfield conditions would remain stable); EPA also examined the potential costs of one regulatory alternative that was considered and rejected: 30-year stability monitoring with no potential to reduce the monitoring duration. EPA chose to propose 30-year long-term stability monitoring with geochemical modeling because this standard has the advantage of being less costly than the 30-year monitoring alternative, and it demonstrates that conditions will remain stable or that conditions down-gradient will trap any mobilized constituents, thus ensuring that groundwater quality is protected. The regulatory alternative of 30-year stability monitoring with no provision to reduce the duration was rejected because it is generally expected to be more costly and less protective than the proposed alternative; even monitoring for 30 years does not guarantee that wellfield conditions will not degrade in the future. The remainder of the economic impact analysis thus focuses on the impacts of EPA's proposed rule. Analytical results for the 30-year stability monitoring with no provision for shortening are found in Appendix D. In addition, Appendix D provides results of a simulation reflecting the possibility that geochemical monitoring will reveal geochemical conditions in and around the wellfield that would not guarantee long-term stability -- a "worst case" cost scenario. If that occurred, we expect regulators to require 30 years of long-term stability monitoring. EPA analyzed the costs and economic impacts that would occur if all ISR facilities had this experience, although that is unlikely to occur in actuality. As noted in Section 3 above, this scenario would only be realized if pre-operational monitoring and geochemical modeling indicated the site was safe to develop, but post-operational sampling and modeling gave a different result. If pre-operational sampling and modeling indicated that conditions are not sufficiently reducing to ensure long-term stability, EPA expects that either the owner operator would choose not to develop, or the licensing authority would not issue a license. Thus, this worst case is unlikely to occur. Based on the proposed 30-year long-term stability monitoring with geochemical modeling using average monitoring costs and assuming that all wellfields are affected, EPA estimated that national total annual costs of complying with the proposed rule would be approximately $13.5 million (see Appendix D for the range of national costs estimated for the geochemical modeling alternative). Compared with the U.S. economy as a whole, these total annual costs are not extremely large. However, the uranium industry is small, with relatively few firms. Compared with the industry sales (estimated to be $3.0 billion in 2015 based on a uranium price of $57 per pound), these estimated total annualized costs comprise about 0.4% of estimated 2015 sales. EPA thus conducted a more in-depth assessment of potential impacts on the market for uranium and on firms in the industry.  5.2	Market Impact Assessment To illustrate likely impacts of the proposed rule on the market for uranium, EPA developed a simplified model of the U.S. market for uranium, using projected quantities of uranium purchased by COOs in 2015, the effective date of the proposed rule. The U.S. Energy Information Administration projects that uranium purchases by U.S. COOs will increase between 2010 and 2040 at a rate of 0.2% per year. Using this rate of growth, EPA estimates that in 2015, COO purchases will have grown from 57.4 million pounds (2013) to 57.6 million pounds. Over the period 2000 to 2013, the share of COO purchases supplied by U.S.-origin uranium averaged 16.4% (EIA, 2014b). Assuming that the share of that quantity coming from domestic-origin uranium in 2015 reflects this historical pattern, EPA estimated that in 2015, COOs will purchase 9.45 million pounds of domestic-origin uranium. Using the projected market price and quantity, EPA applied the costs of complying with the proposed rule and simulated market responses, including changes in market price and quantity, and changes in the share of the market represented by domestic supply and imports. Table 5-1 shows projected 2015 conditions in the U.S. uranium market, which estimate quantities and prices without the proposed rule, and form the basis for the market impact simulations. Table 5-1.	Projected U.S. Uranium Market Conditions, 2015

Market Conditions Supply (million pounds) 57.630 U.S. Origin Uranium 9.451 Foreign Origin Uranium 48.179 Price $57.00

 5.2.1	Market Simulation Model EPA used a partial equilibrium model of the U.S. market for uranium to analyze the impacts of the proposed rule. Market supply is defined as the sum of domestic-origin uranium purchased and foreign-origin uranium. Domestic demand for uranium is a function of the demand for electricity and is represented by projected purchases of U.S. COOs. Figure 5-1 illustrates a market in which some suppliers of the product are affected by the proposed rule and others (such as foreign suppliers) are not. Promulgation of the proposed rule would increase the costs of supplying uranium for ISR facilities, thus shifting their supply curve upward, and the market supply curve upward by a lesser amount. As a result, the with-regulation equilibrium price is slightly higher, and the with-regulation equilibrium market quantity slightly lower. The unit cost of complying with the rule (the vertical shift in the supply curve for affected facilities) is greater than the increase in the market price. Because unaffected facilities respond to the increased market price by increasing the quantity of uranium they supply the market, affected facilities are unable to pass along much of their increased costs to their customers, and the

a) Without-Regulation Equilibrium

b) With Regulation Equilibrium Figure 5-1.	Market Equilibrium Without and With Regulations

profitability of their operations declines. Thus, the quantity of uranium supplied by U.S. ISR facilities declines, while the quantity of uranium supplied by unaffected suppliers increases. The partial equilibrium model used by EPA quantifies estimated market impacts, as described below.  5.2.2	Characteristics of Market Demand for Uranium Uranium is an input into the production of electricity. Thus, the demand for uranium is derived from the demand for electricity. The responsiveness of the demand for uranium to changes in the price of uranium is measured by the elasticity of demand for uranium (computed as the percentage change in the quantity of uranium demanded divided by the percentage change in its price). Elasticity values are typically negative, because increases in price typically cause demanders to want to purchase less of a commodity, if all the other influences on uranium demand are held constant. Elasticity values greater than one in absolute value are termed elastic and indicate demand that is responsive to changes in price. Elasticity values below one in absolute value are termed inelastic. The closer the value is to zero, the less responsive demand is to changes in price. EPA's assessment indicates that the demand for uranium is very inelastic. Economists compute the elasticity of demand for an input as a function of the elasticity of demand for the final product, the elasticity of substitution between the input and other inputs, the elasticity of supply of other inputs, and the cost share of the input as a share of the cost of the final product, in this case electricity. The elasticity of demand for electricity is low, approximately −0.3. The elasticity of substitution between fuels in production of electricity is also low. The cost of uranium typically represents between 0.2% and 0.4% of the cost of electricity. Using these values, we estimated the elasticity of demand for uranium to be about −0.07%. This very low elasticity value indicates that changes in the price of uranium do not result in great changes in the quantity of uranium purchased. Another way of looking at this is to say that the demand for uranium responds less to changes in its price than to other factors affecting demand, such as the share of electricity produced using nuclear power, the price of alternative energy sources for electricity generation, and operating status of U.S. nuclear power plants, for example.  5.2.3	Characteristics of Market Supply The responsiveness of supply to changes in price is similarly measured by an elasticity of supply, computed as the percentage change in quantity supplied divided by a percentage change in price. When price increases, uranium firms will respond by increasing uranium production, because at higher prices, more uranium sources will be profitable to operate. Currently, several ISR facilities are not operating because the market price has been too low to make operation profitable. Further, several ISR facilities are licensed and permitted but have not been constructed. If price rises as projected, some of these sources may be brought online. EPA uses a supply elasticity of two to measure the price-responsiveness of both domestic supply and import supply. Historically, because of the presence of large stockpiles of uranium, supply has been quite responsive to price. However, there is evidence that this is changing, because stockpiles are being drawn down. Thus, in the future, uranium supplied will generally be from recent production, which is expected to be less responsive to price changes than are supplies drawn from inventories or stockpiles. A supply elasticity of two is consistent with values from the literature (University of Chicago, 2004; Ux Weekly, 2004).  5.2.4	Impacts of the Proposed Rule Based on average monitoring costs and assuming 100% of each facility's wellfields are affected simultaneously, implementation of the proposed rule would increase the cost of producing uranium at ISR facilities by $1.50 per pound of uranium. Neither the cost of production using conventional technologies nor the cost of uranium from foreign sources would be affected. Incremental costs of complying with the proposed rule are estimated to be approximately 2.6% of baseline market price. The increased costs incurred by ISR facilities would increase the cost of domestic production overall. Given the characteristics of demand and supply described above, economic theory would predict that the market price of uranium would increase, and the quantity of uranium purchased would fall somewhat. Because imports are a large share of total supply and their costs would not be affected by the rule, domestic suppliers of uranium would have a limited ability to pass the costs of compliance to their customers through price increases. EPA thus estimates that the market price of uranium would increase by only a fraction of the rule's cost per pound, the share of uranium purchased from domestic sources would decline, and the share of foreign-origin uranium imports would increase, if all market conditions other than the proposed rule are held constant.  5.3	Summary of Economic Impact Results Table 5-2 shows EPA's market impact analysis results. These results should be interpreted as an illustration of the relative impacts on the U.S. uranium market as a whole and on domestic suppliers, demanders, and foreign trade, rather than a specific prediction of market outcomes. Using a 2015 projected baseline, initial market quantity is approximately 57.6 million pounds of U3O8, of which an estimated 9.45 million pounds are of domestic origin and 48.2 million pounds are imported. Baseline price is assumed to be $57 per pound. After the market adjusts to costs of compliance with the proposed rule in effect, increasing the costs of ISR production by $1.50 per pound, the overall quantity of uranium demanded by U.S. COOs is projected to decline by about 15.9 thousand pounds (0.03%), and the price of uranium is estimated to increase by approximately $0.24 (0.4%). The quantity of domestic-origin uranium purchased is projected to decline to 9.03 million pounds, a decline of approximately 4.4%, while COO purchases of foreign-origin uranium are estimated to increase by 0.8%. Table 5-2.	Market Impacts of Proposed Rule based on Average Costs, 2014

Baseline 30 Years, Geochemical Modeling to Shorten 30 Years Supply (million pounds)      57,630           57,614           57,612  U.S. origin         9,451             9,032             8,982  Foreign origin      48,179           48,582           48,631  Price ($/pound) $57.00   $57.24   $57.27  Change in price

 $0.24   $ 0.27  Percentage changes

Market quantity

−0.03% −0.03% U.S. origin

−4.4% −5.0% Foreign origin

0.8% 0.9% Price

0.4% 0.5% Incremental cost per pound of uranium

 $1.50   $1.68

 5.4	Employment Impacts of the Proposed Rule According to the U.S. Census Bureau's Statistics of U.S. Business (Census, 2013), in 2011 the uranium and vanadium mining industry had 670 employees. Assuming that employment in the uranium and vanadium industry increases at the same rate as production, employment in 2015 is projected to be 682. Assessing the impact of the proposed rule on employment requires consideration of factors that tend to decrease employment and factors that tend to increase it. Assuming production employment in the U.S. uranium industry declines by approximately the same percentage as output is estimated to decline, EPA estimates that production employment in the U.S. uranium industry would fall by approximately 30 full-time equivalent employees. However, EPA's assessment is that this computation overestimates the decline in employment. First, although ISR is the dominant form of uranium production in the United States, it is less labor intensive than conventional mines and mills. Not all the industry's employees work at ISR facilities, so the actual reduction in ISR facility employment would be smaller than estimated. Further, because of the labor needed to implement the provisions of the proposed rule, EPA expects a countervailing increase in employment in the industry. To comply with the proposed rule, ISR operations may increase their environmental compliance staff to conduct the additional monitoring. To the extent that facilities install more monitoring wells than they would have at baseline, well-drilling employment may also increase. In addition, outside the uranium and vanadium industry, laboratories that analyze groundwater samples may also increase their employment somewhat, in response to an increased demand for analysis. Thus, it is difficult to estimate either the direction or the magnitude of overall employment impacts that would result from the proposed rule.  5.5	Impacts on Small Entities Under the RFA, as amended by SBREFA, EPA is required to evaluate the impacts on small entities affected by its rulemakings. Small entities include small businesses, small governments, and small nonprofits. Small governments and small nonprofits are not expected to be affected by the proposed rule; however, two of the firms owning currently operating ISR facilities, and five additional firms owning planned or standby facilities are small businesses, based on the SBA's criterion for NAICS 212291: 500 or fewer employees. It is important to note that the size determination is made at the owner-company level. Uranium companies frequently have complicated ownership structures, with several layers of ownership. To accurately assess the vulnerability of the firms owning ISR operations, it is the ultimate parent company's size that should be considered. If a small company is actually a subsidiary of a larger company, the impact on the larger company is examined. However, where a larger company is a shareholder in a small company but the small company is nevertheless an independent entity, EPA evaluated the impacts on the small company. EPA assessed the potential for adverse impacts on small businesses by estimating the costs that would be incurred by the firms that own existing facilities, then comparing those estimated costs to the firms' revenues. EPA's guidance on complying with the RFA and SBREFA (2006) establishes criteria for significant impacts: if the proposed rule's costs are less than 1% of sales, impacts are deemed insignificant. If costs exceed 3% of sales, significant impacts are likely. Between 1% and 3% of sales, impacts may or may not be significant. EPA adopted these criteria in determining whether the proposed rule's impacts on small businesses are significant. In Table 5-3, EPA compares the estimated costs for firms owning existing ISR facilities to their sales. Of the four firms owning existing ISR facilities, three are small according to the SBA's definition for NAICS 212291, because they have fewer than 500 employees.   Table 5-3.	Estimated Impacts of the Proposed Rule on Small Entities Parent Company  (ISR Facilities) Small Business Annual Sales (millions USD) Estimated Cost to Sales Ratio

Low  Average  High 30 Years with Geochemical Modeling to Shorten                                                                                Cameco Corporation (Crow Butte, Smith Ranch-Highland-Reynolds)                                       No                                                                        $2,400.0                                      0.4%                                      0.5%                                      0.6% Mestena Uraniuma  (Alta Mesa)                                       Yes                                                                           $28.5                                      1.4%                                      1.7%                                      1.9% Uranium One, Inc. (Willow Creek)                                       No                                                                          $530.4                                      0.1%                                      0.1%                                      0.1% Uranium Energy Corp.a  (Hobson-La Palangana)                                       Yes                                                                           $28.5                                      0.9%                                      1.1%                                      1.2% Ur-Energy (Lost Creek)                                       Yes                                                                           $57.0                                      0.6%                                      0.6%                                      0.7% 30 Years, No Option to Shorten                                                                                Cameco Corporation (Crow Butte, Smith Ranch-Highland-Reynolds)                                       No                                    $2,400.0                                      0.5%                                      0.5%                                      0.6% Mestena Uraniuma  (Alta Mesa)                                       Yes                                      $28.5                                      1.6%                                      1.9%                                      2.2% Uranium One, Inc. (Willow Creek)                                       No                                     $530.4                                      0.1%                                      0.1%                                      0.1% Uranium Energy Corp.a  (Hobson-La Palangana)                                       Yes                                      $28.5                                      1.0%                                      1.2%                                      1.4% Ur-Energy (Lost Creek)                                       Yes                                      $57.0                                      0.6%                                      0.7%                                      0.9% [a] To assess impacts on the small firms companies based on typical operations, EPA estimated sales revenues based on the facility's estimated production and market price. For the two large firms, 2013 reported sales were used. small firm, Mestena Uranium, no data on sales are available. EPA estimated Mestena's 2015 sales revenues by first estimating their production, then multiplying estimated production times the projected 2015 price of uranium. For Mestena's Alta Mesa ISR operation, EPA estimated 2015 production to be 500,000 pounds. At $57 per pound, which is the projected price of U3O8 in 2015, Mestena's estimated revenue from uranium sales would be $28.5 million. Another small firm, Uranium Energy Corporation (UEC), reported that it had sold 220,000 pounds of uranium in 2013 for $9.0 million. Based on projections that the market for uranium will have recovered somewhat by 2015, EPA estimates that UEC also will sell 500,000 pounds of U3O8 in 2015, with estimated revenues of $28.5 million. The third small business, Ur-Energy, stated in its 2013 Annual Report that it planned to sell 1,000,000 pounds of U3O8 from its Lost Creek operation in 2014. EPA thus assumed that 2015 production at Lost Creek would again be 1,000,000 pounds and that Ur-Energy's revenues for the year would be $57 million. For the two large firms, Cameco and Uranium One, EPA used 2013 reported sales as the estimate for 2015 sales. EPA's analysis estimates that average estimated costs of complying with the proposed rule represent between 0.6% and 1.9% of estimated revenues for the three small businesses, and between 0.1% and 0.6% of revenues for the two businesses that are not small. Even using the high estimated costs and making the unrealistic assumption that 100% of facilities' acreage would be involved in operations regulated under the proposed rule at a given time, the maximum cost-to-sales ratio is 1.9%. For none of the firms analyzed does EPA's analysis indicate that costs of the proposed rule would exceed 2% of company sales revenues. EPA has chosen to analyze the possible impacts on companies owning ISR facilities using information about the companies that own existing ISR operations because they are believed to be representative of companies that may own ISR facilities in the future. EPA examined financial information for some firms that own planned facilities. However, it is unclear when and indeed whether these ISR facilities may begin producing uranium. Without this information about planned production, EPA was unable to include them in the analysis. Thus, the results in Table 5-3 include only firms that own existing ISR facilities. Using these companies as representative of companies that may own ISR facilities affected by the proposed rule and estimating revenue for the small firms based on estimated production in 2015, EPA found that their costs would be between 0.6% and 1.9% of firm revenue, based on average compliance costs, and at most 2.2% based on high-cost estimates. Further, EPA estimates that fewer than 10 small businesses would be affected by the proposed rule at any time in the future. Thus, EPA thus does not expect the costs of complying with the proposed rule to result in significant impacts to a substantial number of small firms. 5.6	Uncertainties For a given ISR operation, the costs of complying with the proposed rule are a function of the characteristics of the wellfields at that operation. Unfortunately, EPA does not have detailed descriptions of the mine units at existing ISR operations and thus cannot directly estimate the costs that would be incurred for individual wellfields. Instead, EPA estimated the costs of complying with the proposed rule for a CMU and scaled the costs up, proportional to total acreage, to estimate the costs for each ISR facility. This approach implies that costs are a function of wellfield size and does not take into account the other facility-specific factors that would affect costs. For example, in the case of a site composed of more than one distinct ore zone within its footprint, costs would be underestimated because more monitoring and sampling would be conducted than assumed in the scaling calculations reported here. Unfortunately, in the absence of wellfield-specific data, EPA is unable to assess whether costs for a particular ISR facility are overestimated or underestimated. EPA estimated the costs of undertaking additional monitoring at the pre-operational, operational, restoration, stability, and long-term stability monitoring stages. Incremental costs were computed by subtracting estimated costs of current compliance practices from the estimated costs of compliance under the proposed rule. EPA recognizes that many of the provisions of the proposed rule are embodied in existing permits and licenses. Therefore, the incremental costs of the proposed rule are somewhat overstated. However, EPA is unable to determine the exact magnitude of this effect. EPA has analyzed the potential economic impacts of the proposed rule and possible impacts on both small and large owner companies using information about the projected 2015 conditions in the market for uranium and companies owning existing ISR facilities. The proposed rule will take effect in 2015 and affect ISR facilities that operate from that time, going forward. Conditions in the uranium market are volatile; the price of uranium and the market share of U.S. producers have historically been variable. The market price of uranium is projected to increase to about $57 per pound of U3O8 equivalent, from a 2013 price of about $52 per pound. If that occurs, several of the facilities that are currently idle or that are in the process of being licensed may begin production. Revenues for firms owning ISR uranium facilities would certainly increase, if both production and price rises. However, EPA is unable to estimate how those changes would affect estimated market impacts and impacts on small entities and has made conservative assumptions about the quantities of U3O8 that would be produced by these facilities. Also, although the EIA projects that both purchases of uranium and its price will increase by 2015, the price of uranium has recently been declining, because of the combined influences of the Fukushima earthquake and tsunami and the global economic downturn. If the market for uranium does not recover as projected, 2015 conditions could reflect lower purchases and prices than are estimated in this study. EPA used publicly available sales revenue data for two large firms owning ISR facilities. For the small entities, EPA first estimated 2015 production by estimating 2015 production levels based on their capacity and recently reported production levels, adjusted to reflect somewhat higher prices and production in 2015. EPA then estimated revenues for these firms by multiplying the estimated production times the projected 2015 price of $57 per pound. These estimates are thus based on EPA's projections of 2015 conditions in the uranium market; both production and the price of uranium in 2015 are uncertain.      Statutory and Executive Order Reviews  6.1	Synopsis This section summarizes the statutory and Executive Order (EO) impact analyses relevant for Proposed Revisions to 40 CFR Part 192, Health and Environmental Protection Standards for Uranium and Thorium Mill Tailings. For each EO and statutory requirement, we describe both the requirements and the way in which our analysis addresses these requirements. EPA has concluded that ISR uranium facilities, if not adequately monitored during and after operations, have the potential to pollute adjacent groundwater aquifers if geochemical conditions in the wellfield change after restoration so that uranium is once again mobilized. Such pollution would potentially impose costs on people who are neither buyers nor sellers of uranium (thus, external to the market) who may be exposed to pollutants in down-gradient aquifers. Externalities such as pollution are one type of market failure, which requires regulatory intervention to ensure that social benefits of uranium production exceed social costs of its production. 6.2	Executive Order 12866: Regulatory Planning and Review and Executive Order 13563: Improving Regulation and Regulatory Review Under EO 12866 (58 FR 51735, October 4, 1993), this action is a "significant regulatory action." The EO defines "significant regulatory action" as one that is likely to result in a rule that may "raise novel legal or policy issues arising out of legal mandates, the President's priorities, or the principles set forth in the Executive Order." White House Office of Management and Budget Circular A-4, Regulatory Analysis, requires government agencies to consider market failure "to the extent permitted by law and where applicable."  In market transactions where information is equally available to buyers and sellers, all costs and benefits are borne by either buyers or sellers and there are enough buyers and sellers to ensure competition, markets will efficiently allocate resources so that, from society's point of view, the net benefits of the market transactions are maximized. However, in situations where production of a commodity such as uranium produces pollution, people who are external to the market (neither buyers nor sellers in the market) for uranium may be exposed to uranium and thus bear costs. These external costs or negative externalities are one example of market failure and are the underlying justification for government regulatory intervention in such markets. Based on its examination of hydrogeology and geochemistry at ISR sites and its review of publicly available information about ISR mining operations, EPA believes that ISR operations pose a risk of contaminating groundwater and having the contamination remain undetected for years, if sufficient post-restoration monitoring is not done. Because ISR uranium mining poses the potential for external costs and is thus affected by market failure, EPA is required by EO 12866 to develop this proposed rule and to examine its economic impacts, costs, and benefits to ensure that its benefits to society exceed its costs. Thus, EPA has conducted this economic analysis to examine the costs, benefits, and estimated impacts of the proposed rule. EPA's study estimates that affected ISR operators would incur costs to comply with the proposed rule, which would require comprehensive pre-operational characterization of the site (including characterization of geochemical conditions down-gradient of the production zone), careful monitoring during the operation, restoration of groundwater quality, at least 3 years of stability monitoring, and 30 years of long-term stability monitoring, with the potential to shorten the duration based on modeling and monitoring of down-gradient geochemical conditions. Using existing ISR operations as models for ISR operations that would be affected by the rule, projecting that 2015 ISR uranium production will be 8.95 million pounds, and using average estimated costs of complying with the proposed rule, EPA estimates that the proposed rule would increase the average cost of uranium production at ISR facilities by approximately $1.50 per pound of uranium and that annual costs incurred by individual ISR facilities would vary from $303,000 to $9.5 million, depending on the scale of the ISR. Nationally, EPA estimates that the incremental total annual cost of the proposed rule would be approximately $13.5 million. Discounted at 7%, the estimated present value of the stream of national costs would be approximately $181 million. Discounted at 3%, the estimated present value of national costs would be approximately $290 million. EPA also examined the costs that would be incurred under a regulatory option that would require 30 years of long-term stability monitoring with no option for shortening the duration using geochemical modeling. National total annualized cost under this alternative is slightly higher, an estimated $15.1 million. The estimated discounted present value of costs (discounted at 7%) would be approximately $203 million; discounted at 3%, the estimated present value of costs under this alternative would be approximately $420 million. Please see Appendix D for a sensitivity analysis of estimated costs and impacts of the proposed rule and the 30-year long-term stabilization monitoring alternative. EPA conducted a qualitative assessment of the benefits of the proposed rule. The rule would require thorough characterization of baseline conditions within the ore zone and surrounding aquifers and would put in place an automatic updating feature so that the requirements affecting ISR operations are always consistent with requirements of SDWA and RCRA. Further, EPA's proposed rule would require a longer period of monitoring, 30 years, to ensure that conditions in the exempted aquifer had been restored, had achieved steady state, and were stable. Further, EPA allows facilities to use geochemical modeling to demonstrate that groundwater conditions will remain stable and thereby reduce the duration of stability monitoring to less than 30 years. These provisions help ensure that, after the ISR operation's license is terminated and the site is closed, groundwater conditions do not deteriorate. Groundwater is a valuable resource, particularly in the western United States where ISR uranium mining is most common. Although EPA is unable to quantify the value of the groundwater resources that would be protected by the proposed rule, EPA nevertheless believes that the groundwater resources are likely to become more valuable over time. Reducing the risk of contamination of groundwater also protects surface water bodies to which it discharges. If groundwater near an ISR facility were to become contaminated due to remobilization of uranium and other constituents, it might be many years before the contamination was discovered, especially under current practice where stability monitoring typically lasts only a year or two. One way to illustrate the potential benefits of the proposed rule is to estimate the costs of corrective action that would be required if contamination occurred. If the proposed rule prevents the contamination (or causes it to be discovered sooner), it would reduce the corrective action costs incurred to remediate the contamination. EPA estimated potential contamination and associated corrective action costs for the CMU under various assumptions. The costs of remediation far exceed the costs of complying with the proposed rule, both on an annualized basis and as a present value. Using a hydrological model, EPA estimated that cleaning up the plume of contamination could require 100 years of pump and treat remediation. In addition, if contamination were detected after decommissioning of a site, the costs of remediation could be borne by the taxpayer or by the owner of the property, rather than the uranium company responsible, if the former owner company were no longer in existence. Because we cannot anticipate how many ISR operations might experience deteriorating groundwater conditions after decommissioning or how long it would be before the contamination would be detected, EPA is unable to estimate what the national cost savings resulting from avoided remediation costs might be. However, EPA believes they could be substantial. In addition to cost savings, the proposed rule has the potential to protect human and ecosystem health. Since a closed ISR facility has no regulatory oversight, this provision would reduce the risks of unintended exposure of human and ecological receptors to chemical and radiological constituents. To the extent that such exposures are reduced, associated human health risks such as cancer may also be reduced.  6.3	Paperwork Reduction Act EPA has determined that this action does not impose an information collection burden under the provisions of the Paperwork Reduction Act, 44 U.S.S. 3501 et seq. Burden is defined at 5 CFR 1320.3(b).  6.4	Regulatory Flexibility Act The RFA generally requires an agency to prepare a regulatory flexibility analysis of any rule subject to notice and comment rulemaking requirements under the Administrative Procedure Act or any other statute unless the agency certifies that the rule will not have a significant economic impact on a substantial number of small entities. Small entities include small businesses, small organizations, and small governmental jurisdictions. For purposes of assessing the impacts of the proposed rule on small entities, small entity is defined as (1) a small business whose company has fewer than 500 employees and is primarily engaged in leaching or beneficiation of uranium, radium, or vanadium ores as defined by NAICS code 212291; (2) a small governmental jurisdiction that is a government of a city, county, town, school district, or special district with a population of less than 50,000; and (3) a small organization that is any not-for-profit enterprise that is independently owned and operated and is not dominant in its field. Of these three categories, only small businesses are potentially affected by the proposed rule; no small organizations or small governmental entities have been identified that would be impacted by the proposed revisions to Part 192. This proposed rule is estimated to impact approximately 19 ISR uranium recovery facilities that are currently operating or may operate in the future. The 19 uranium recovery facilities are owned by 10 firms, of which eight are believed to be small. To evaluate the significance of the economic impacts of the proposed revisions to Part 192, EPA estimated the costs that would be incurred by existing facilities, based on their estimated production and EPA's estimated cost per pound of U3O8. According to EPA's Final Guidance for EPA Rule Writers: Regulatory Flexibility Act as Amended by the Small Business Regulatory Enforcement Fairness Act (EPA, 2006), firms for which estimated costs of complying with a rulemaking are less than 1% of firm sales are presumed not to incur significant impacts. Firms for which costs exceed 3% of firm's baseline sales are believed to incur significant impacts. If costs of compliance are between 1% and 3% of the firm's revenue, it is not certain whether impacts would be significant. To analyze the proposed revisions to Part 192, EPA assessed potential impacts to six currently operating ISRs, believing that they are good proxies for firms that would own affected ISR facilities subject to the proposed rule. The operating ISRs are Crow Butte and Smith Ranch-Highland-Reynolds owned by Cameco Resources, Alta Mesa owned by Mestena Uranium, LLC, Willow Creek owned by Uranium One, Inc., Hobson-La Palangana owned by Uranium Energy Corp, and Lost Creek owned by Ur-Energy Corporation. Using the fewer than 500 employees' criterion, Mestena Uranium, LLC, Ur-Energy Corporation, and Uranium Energy Corporation are small businesses, while Cameco Resources and Uranium One, Inc. are both large businesses. In addition to the six operating ISRs, 12 ISRs have are at some stage of planning or licensing, or are undergoing restoration: Dewey-Burdock owned by Powertech Uranium Corp.; Nichols Ranch owned by Uranez Uranium Corp.; Moore Ranch and Antelope-Jab, owned by Uranium One, Inc.; Crownpoint, Kingsville Dome, Rosita, Church Rock, and Vasquez all owned by Uranium Resources; Ross, owned by Strata Energy/Peninsula Energy Ltd; Goliad, owned by Uranium Energy Corp; and Reno Creek, owned by Bayswater E&P. All of these companies, except Uranium One, Inc., are small businesses. Of the facilities identified above, 11 are owned by eight small businesses. EPA's economic impact analysis estimated that for the small firms currently operating ISR facilities, costs of the proposed rule would be at most 0.7% of estimated 2015 operating revenues for Ur-Energy, at most 1.2% of estimated 2015 operating revenues for Uranium Energy, and at most 1.9% of estimated 2015 operating revenues for Mestena, if the highest-cost assumptions were used. Based on EPA's criteria for significance, impacts for these firms are not believed to be significant. In addition, the number of firms potentially incurring costs to comply with the rule is not a substantial number. Thus, EPA concludes that the proposed rule would not result in a significant impact to a substantial number of small entities. (See Section 5.5 above for additional details.)  6.5	Unfunded Mandates Reform Act (UMRA) This rule does not contain a federal mandate that may result in expenditures of $100 million or more for state, local, and tribal governments, in the aggregate, or the private sector in any 1 year. Using the five existing ISR operations as examples of typical ISR facilities, EPA estimates that total annual costs of complying with the rule for five such ISR facilities would range from $11.6 million to $15.2 million, averaging $13.5 million, assuming geochemical modeling to shorten the duration, and between $12.9 and $17.9, averaging $15.1 for required 30-year duration of long term stability monitoring. The proposed rule imposes no enforceable duties on any state, local, or Tribal governments or the private sector. Thus, this rule is not subject to the requirements of sections 202 or 205 of UMRA. This rule is also not subject to the requirements of section 203 of UMRA because it contains no regulatory requirements that might significantly or uniquely affect small governments because it contains no requirements that apply to such governments nor does it impose obligations upon them.  6.6	Executive Order 13132: Federalism This proposed rule does not have federalism implications. It will not have substantial direct effects on the states, on the relationship between the national government and the states, or on the distribution of power and responsibilities among the various levels of government, as specified in EO 13132. None of the facilities subject to this action are owned and operated by state governments, and, nothing in the proposed rule will supersede state regulations. Thus, EO 13132 does not apply to this proposed rule.  6.7	Executive Order 13175: Consultation and Coordination with Indian Tribal Governments This action does not have tribal implications, as specified in EO 13175 (65 FR 67249, November 9, 2000). The action imposes requirements on owners and operators of ISR facilities and not tribal governments. Although EO 13175 does not apply to this action, EPA sought opportunities to provide information to tribes and tribal representatives during the review of 40 CFR Part 192. EPA specifically solicits additional comment on this proposed action from tribal officials.  6.8	Executive Order 13045: Protection of Children from Environmental Health Risks and Safety Risks EPA interprets EO 13045 (62 FR 19885, April 23, 1997) as applying to those regulatory actions that concern health or safety risks, such that the analysis required under section 5-501 of the Order has the potential to influence the regulation. Because this action addresses environmental standards intended to mitigate health or safety risks, it is subject to EO 13045. We evaluated several regulatory strategies for ensuring groundwater restoration and stability at ISR facilities and selected the option providing most assurance that groundwater systems will remain in a chemically reduced state, thereby limiting contamination of groundwater. The proposed rule is expected to reduce children's risk of exposure to contaminated groundwater by improving monitoring to detect and correct contamination.  6.9	Executive Order 13211: Actions Concerning Regulations That Significantly Affect Energy Supply, Distribution or Use This action is not a "significant energy action" as defined in EO 13211 (66 FR 28355, May 22, 2001), because it is not likely to have a significant adverse effect on the supply, distribution, or use of energy. This proposed rule will not adversely directly affect productivity, competition, or prices in the energy sector. EPA projects that the proposed rule would reduce the quantity of uranium used in this country to produce electricity by less than 0.1%. The price of uranium is projected to increase by only $0.24 (0.4%) per pound, and this is projected to increase the cost of producing electricity by less than 0.1%.  6.10	National Technology Transfer and Advancement Act Section 12(d) of the National Technology Transfer and Advancement Act (NTTAA) of 1995 ("NTTAA"), Public Law No. 104-113, 12(d) (15 U.S.C. 272 note) directs EPA to use voluntary consensus standards in its regulatory activities unless to do so would be inconsistent with applicable law or otherwise impractical. Voluntary consensus standards are technical standards (e.g., materials specifications, test methods, sampling procedures, and business practices) that are developed or adopted by voluntary consensus standards bodies. NTTAA directs EPA to provide Congress, through OMB, explanations when the Agency decides not to use available and applicable voluntary consensus standards. This proposed rulemaking does not involve technical standards of the type indicated in NTTAA. Therefore, EPA is not considering the use of any voluntary consensus standards. We request public comment on this aspect of the proposed rulemaking, and specifically, ask you to identify potentially applicable voluntary consensus standards and to explain why such standards could be used in this regulation.  6.11	Executive Order 12898: Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations EO 12898 (59 FR 7629, Feb. 16, 1994) establishes federal executive policy on environmental justice. Its main provision directs federal agencies, to the greatest extent practicable and permitted by law, to make environmental justice part of their mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority populations and low-income populations in the United States. EPA has determined that this proposed rule will not have disproportionately high and adverse human health or environmental effects on minority or low-income populations because it increases the level of environmental protection for all affected populations without having any disproportionately high and adverse human health or environmental effects on any population, including any minority or low-income population. This proposed rule addresses groundwater restoration, monitoring, and protection of surrounding aquifers and thus decreases the potential groundwater contamination to which all affected populations are exposed. Thus, the proposed rule is projected to have positive, not adverse, impacts on human health and the environment.

      Conclusions EPA is proposing revised groundwater monitoring program for ISR facilities that produce uranium by injecting and extracting a solution that dissolves the uranium from the porous minerals in which it is found. ISR uranium production represents an increasing share of uranium production, and poses special groundwater protection challenges, compared to conventional uranium production. Currently, facilities are required to monitor groundwater conditions for only a short time (generally less than 2 years) after restoration. Case studies of post-restoration monitoring conducted by the U.S. Geological Survey (USGS, 2009) have shown that conditions may not remain stable within restored wellfields, with concentrations of some constituents increasing again. Thus, there is a potential for uranium and other constituents to remobilize over time, with the potential for groundwater contamination. Accordingly, EPA is proposing to add a new subpart to 40 CFR Part 192, establishing additional monitoring requirements during all phases of an ISR facility: Pre-operational monitoring: measuring background groundwater concentrations Operational monitoring: monitoring, to detect any excursions of contaminated groundwater to adjacent aquifers, either beside, above, or below the exempted aquifer Restoration monitoring: monitoring to document the progress of restoration through groundwater sampling Post-restoration monitoring, which has two parts: Stability monitoring: monitoring, conducted after restoration efforts have ended, to establish that wellfield groundwater characteristics are stable and meet restoration goals (at least 3 years) Long-term stability monitoring: monitoring and statistical analyses to show that the concentration of each monitored constituent is not increasing with time and that the concentration is not statistically different from the restoration goal Using a model facility approach, EPA estimated the costs that facilities may incur to comply with the proposed rule; costs were estimated for each phase of ISR operation under two regulatory options, and a range of costing assumptions. Cost data were compiled for each stage over the duration of the stage's monitoring activities for the CMU, then scaled up based on relative total wellfield acreage to estimate the costs that would be incurred by existing facilities. EPA estimated the acreage of the CMU and scaled estimated CMU costs up to actual facility costs using the ratio of total wellfield acreage at existing facilities to acreage of the CMU. These estimated facility costs were used to assess impacts on the market for uranium and on firms owning ISR facilities. The market for uranium is an international market, with suppliers and demanders in many countries. The United States has historically been the largest user of uranium for electricity production but has generally produced only a small share of what it consumes, and foreign suppliers have provided the remaining 80% to 90%. The uranium market has historically been volatile, exhibiting considerable year-to-year variation in both price and domestic production. Going forward, the worldwide demand for uranium is projected to grow substantially over the next 20 years, due largely to increased demand from China and India; prices are also projected to increase to $64 per pound by 2018. The U.S. EIA projects that uranium purchased by COOs of nuclear power plants will grow by approximately 0.2% annually. Using this rate of growth, EPA projected baseline market conditions in the U.S. uranium market in 2015, the effective date of the proposed rule. EPA estimated the impact of the proposed rule on the market for uranium and found that, overall, the market quantity of uranium purchased for use in electric generation would decline by less than 0.1% and the market price would increase by approximately 0.4%. Domestic ISR facilities would decrease their production by approximately 4.1%, and imports of uranium would increase by less than 1%. Because the cost of uranium is a very small share of the cost of electricity, EPA estimates that the cost of generating electricity would increase by less than 0.1%. Although the national total annual costs of the proposed rule (approximately $13.5 million, based on average costs) is well below the $100 million threshold that is one of the criteria used to identify a significant regulatory action, the industry has only a small number of companies operating a small number of ISR operations. EPA used existing ISR operations and the companies that own them as models for the types of facilities and companies that would likely be affected by the proposed rule. EPA thus estimated the ISR facilities would incur annual costs of compliance between $262,000 and $12.7 million depending on the characteristics of the ISR facility and the alternative and costing assumptions used; for small firms owning ISR facilities, EPA's analysis estimates cost-to-sales ratios of 0.6% to 2.2%, depending on the size of the operation and the costing assumptions used. Because EPA does not estimate costs to exceed 2.2% of small company sales, and because fewer than 10 small companies would be affected, EPA has determined that the proposed rule would not have a significant impact on a substantial number of small entities. EPA's qualitative benefits assessment presents a discussion of the expected effects of the proposed rule on human and environmental health. EPA expects that the improved monitoring program proposed will reduce the risk of contaminating groundwater resources, thus also reducing potential exposures to radiological and nonradiological contaminants in groundwater and potentially in surface water to which affected aquifers discharge. Because the major risk of exposure to radiological constituents is cancer, the proposed rule has the potential to reduce cancer risks. If uranium and other constituents remobilize in groundwater over time and if monitoring ends too soon and sites are prematurely decommissioned, it is possible that groundwater in surrounding aquifers could be contaminated, and it might be many years before the contamination is detected. EPA simulated groundwater contamination using its CMU model facility under varying assumptions and estimated the costs of corrective action to remediate the groundwater contamination. Based on these simulations, the cost of remediation would far exceed the costs of complying with the proposed rule, both on an annual and total basis. For the model facility simulation, this subset of benefits (avoided remediation costs) exceeded the costs of complying with the proposed rule. See Table 7-1 for this comparison. Further, if contamination were detected after decommissioning, the costs of remediation could be borne by the taxpayer or the land owner, not the uranium company owner/operator (if, for example, the former owner company were no longer in existence or if sufficient time had passed that the connection between the contamination and the decommissioned mining operation was not identified). EPA was unable, however, to estimate potential avoided costs of remediation on a national scale and thus was unable to quantify the rule's net benefits nationwide. Table 7-1.	Comparison of Costs of Complying with the Proposed Rule and Costs of Remediating Contaminated Groundwater (Million 2011$) Plume Size and Groundwater Flow Direction Sum of Costs Over Time

Without-Regulation Scenario (A)           With-Regulation: Compliance and Additional Restoration (B) Avoided Costs (A) − (B) Small plume $35.3                                      $27.1 $8.2 Large plume, transverse $481.0                                      $27.1 $453.9 Large plume, along $586.1                                      $27.1 $559.0

                               Annualized Costs

Small plume

                                 $1.45 million

Large plume, transverse

                                 $10.3 million

Large plume, along

                                 $10.5 million

Compliance with proposed rule plus additional restoration

                                   $345,000

 References Aquatic & Consulting Testing Inc. (ACTI), 2005. "Biological and Analytical Chemistry Services." Available at: http://www.aquaticconsulting.com/fee%20schedule.pdf [Accessed March 23, 2013]. Australian Government. Department of Resources, Energy and Tourism (DRET), 2010. Australia's In Situ Recovery Best Practice Guide: Groundwaters, Residues, and Radiation Protection. http://www.ret.gov.au/resources/Documents/Mining/uranium/In-situ-uranium.pdf Australian Uranium Association, 2013. Expect nuclear power capacity and uranium prices, consumption and production to increase. http://www.aua.org.au/Content/NuclearUraniumForecasts.aspx Bureau Veritas North America (BVNA), 2010. "Schedule 66, Scientific Equipment and Services," Number: GS-07F-6029R, Period: 17 Aug 2010  - 17 Aug 2015. Cameco Resources, 2008. Drawing OP-1 2008, Layout of Smith Ranch-Highlands Operation. Attachment to 2008 Annual Report submitted to the Nuclear Regulatory Commission June 30, 2008. http://pbadupws.nrc.gov/docs/ML0820/ML082060217.html Cameco, Incorporated. 2013. The Strength to Dig Deeper.  2013 Annual Report. http://www.cameco.com/investors/financial_information/annual_reports/2013/  Cooperative Chemical Analytical Laboratory (CCAL), 2012. "CCAL Fee Schedule for FY13." Available at: http://www.ccal.oregonstate.edu/fees.htm [Accessed March 23, 2013]. Davis, J.A. and G.P. Curtis, 2007. NUREG/CR - 6870, "Consideration of Geochemical Issues in Ground Water Restoration at Uranium In-Situ Leaching Mining Facilities." Washington, DC: Nuclear Regulatory Commission. DBS&A (Daniel B. Stephens and Associates, Inc.) Energy Laboratories Inc. (ELI), 2013. "Technical Services and Fee Schedule 2013." Available at: http://www.energylab.com/asp/PricingGuide/docs/ELI_2013_Fee_Schedule_-_ALL_SECTIONS_v0.pdf [Accessed March 23, 2013]. Energy Laboratories, Inc. (ELI), 2011. "Analytical Services 2011." McDonald, M.G., and A.W. Harbaugh, December 28, 1983. A modular three-dimensional finite-difference ground-water flow model. Open-File Report 83-875. U.S. Geological Survey. McWorter, D.B. and D.K. Sunada, 2010. Ground-Water Hydrology and Hydraulics; Water Resources Publications, LLC; ISBN-10:<PHONE_NUMBER>; ISBN-13:<PHONE_NUMBER>612; 304 pages. Michel, T.G. and G. Hoffman, July 1991. E-Field 50 Sand Mine Unit Hydrology Test, Highland Uranium Project, Power Resources, Inc.; Report for WDEQ/LQD Permit Number 603, U. S. Nuclear Regulatory Commission Docket Number 40-8857, SUA-1511; Report by Power Resources, Inc. and Hydro-Engineering; September 1990, revised July 1991. Midwest Laboratories (ML), 2013. "Schedule of Fees 2013." Available at: https://www.midwestlabs.com/wp-content/uploads/2013/01/Midwest-Labs-Schedule-of-Fees-2013.pdf [Accessed March 23, 2013]. National Academy of Sciences (NAS), 1997. Valuing Groundwater: Economic Concepts and Approaches. Committee on Valuing Groundwater, National Research Council. Nebraska Department of Health and Human Services (NDHHS), 2010. "Analyte/Price List, Nebraska NDHHS Laboratory 2009-10." North American Industry Classification System (NAICS), 2012. http://www.naics.com/free-code-search/naicsdescription.php?code=21229. Accessed August 2012. Pace Analytical Services Inc., 2009. "Minneapolis, MN Laboratory, 2009 Pricing Information," Revised 1/1/09. Pearson, F.J., Jr., C. J. Noronha and R.W. Andrews, 1983. "Mathematical Modeling of the Distribution of Natural 14-C, 234-U, and 238-U in a Regional Ground-Water System," Radiocarbon, Vol.25, No. 2, p 291-300. Peel, G., July 30, 2012. Uranium Price Upside Ahead: Raymond James Forecast. FNArena. http://finance.ninemsn.com.au/newscolumnists/greg/8507872/uranium-price-upside-ahead Peninsula Energy Limited  -  2013 Annual Report. http://www.pel.net.au/images/peninsul---doojahruxo.pdf  Peninsula Energy Ltd., 2012. 2011 Annual Report. http://www.pel.net.au/investor_info/annual_reports.phtml Poe, G., K. Boyle, and J. Bergstrom, 2001. "A Preliminary Meta Analysis of Contingent Values for Groundwater Quality Revisited." In The Economic Value of Water Quality. J. Bergstrom, K. Boyle, and G. Poe, eds. Northampton, MA: Edward Elgar. Pravda, 2012.Russia Delivers Uranium to U.S. Nuclear Power Plants. By Anatoly Miranovsky. http://english.pravda.ru/russia/economics/17-07-2012/121660-russia_usa_nuclear-0/ Reilly, T.E., K.F. Dennehy, W.M. Alley, and W.L. Cunningham, 2008. Ground-Water Availability in the United States: U.S. Geological Survey Circular 1323, 70 p., also available online at http://pubs.usgs.gov/circ/1323/ Shafer, D., R. Bush, W. Dam, and T. Pauling, March 2014. The Future is Now: Experience with Remediating and Managing Groundwater Contamination at Uranium Mill Tailing Sites  -  14587. Presented at the WM2014 Conference, March 2-6, 2014, Phoenix, AZ. San Antonio River Authority, 2012. "Analytical Services Fee Schedule." Available at: http://www.sara-tx.org/public_services/laboratory_services/docs/Fee-schedule-2012.pdf [Accessed March 23, 2013]. Texas Department of State Health Services (TDSHS), 2007. "2007 TDSHS Fee Schedule -- Austin Lab," CLIA ID #: 45D0660644, Tax ID # 32-0113643. U.S. Census Bureau, 2013. Statistics of U.S. Business. 2011. http://www.census.gov/econ/susb/ U.S. Department of Energy, 2013. Cost and Time Metric Tool (Web Application); National Renewable Energy Laboratory; Internet resource: http://en.openei.org/wiki/Exploration_Cost_and_Time_Metric U.S. Energy Information Administration (EIA), 2013a. 2012 Domestic Uranium Production Report. http://www.eia.gov/uranium/production/annual/ U.S. Energy Information Administration (EIA), 2013b. 2012 Uranium Marketing Annual Report. http://www.eia.gov/uranium/marketing/ U.S. Energy Information Administration, May 2003. 1993 - 2002-Uranium Industry Annual 2002. U.S. Energy Information Administration: 1994 - 2002-Uranium Industry Annual, Tables 10, 11 and 16. 2003 - 2011-Form EIA-858, "Uranium Marketing Annual Survey." U.S. Energy Information Administration: Form EIA-851A, "Domestic Uranium Production Report" (2003 - 2011). U.S. Energy Information Administration: Form EIA-851A, "Domestic Uranium Production Report" (2007 - 2011). U.S. Energy Information Administration, 2014a. Annual Energy Outlook 2014 with projections to 2040, May 7, 2014. http://www.eia.gov/forecasts/aeo/index.cfm?src=Nuclear-f3 U.S. Energy Information Administration, 2014b. Domestic Uranium Production Report  -  Annual. May 1, 2014. http://www.eia.gov/uranium/production/annual/ U.S. Energy Information Administration, 2014c. Uranium Marketing Annual Report. May 12, 2014. http://www.eia.gov/uranium/marketing/ U.S. Environmental Protection Agency (EPA), 2012a. Considerations Related to Post Closure Monitoring of Uranium In-Situ Leach/In-Situ Recovery (ISL/ISR) Sites: Background Information Document for the Revision of 40 CFR Part 192. Radiation Protection Division, Office of Air and Radiation. U.S. Environmental Protection Agency (EPA), 2012c. Groundwater Modeling Studies at In Situ Leaching Facilities and Evaluation of Doses and Risks to Off-Site Receptors from Contaminated Groundwater. U.S. Environmental Protection Agency (EPA), 2012d. Importance of Water Study. http://water.epa.gov/action/importanceofwater/study.cfm. U.S. Environmental Protection Agency (EPA), 2013. "Considerations Related to Post Closure Monitoring of Uranium In-Situ Leach/In-Situ Recovery Sites." U.S. Environmental Protection Agency (EPA), December 2010. Guidelines for Preparing Economic Analyses. U.S. Environmental Protection Agency (EPA), March 26, 2012b. Data collected (WA 2-04, Task B) and provided by EPA. U.S. Environmental Protection Agency (EPA), November 2006. Final Guidance for EPA Rulewriters: Regulatory Flexibility Act as amended by the Small Business Regulatory Enforcement Fairness Act. http://www.epa.gov/sbrefa/documents/Guidance-RegFlexAct.pdf U.S. Geological Survey. 2009. Groundwater Restoration at In-Situ Recovery Uranium Mines, South Texas Coastal Plain. Open File Report 2009-1143. Written by Susan Hall. http://pubs.usgs.gov/of/2009/1143/  U.S. Nuclear Regulatory Commission, 1997. Final Environmental Impact Statement to Construct and Operate the Crownpoint Uranium Solution Mining Project, Crownpoint, New Mexico. NUREG-1508. U.S. Nuclear Regulatory Commission, Washington, DC. U.S. Nuclear Regulatory Commission, 2009. Generic Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities. NUREG-1910, Final Report, Chapters 1 through 4. U.S. Nuclear Regulatory Commission, Washington, DC. U.S. Nuclear Regulatory Commission, 2012b. Uranium Recovery. http://www.nrc.gov/materials/uranium-recovery.html Accessed July 2012. U.S. Nuclear Regulatory Commission, 2013. Part 40: Domestic Licensing of Source Material, available at http://www.nrc.gov/reading-rm/doc-collections/cfr/part040/, and Appendix A to Part 40: Criteria Relating to the Operation of Uranium Mills and the Disposition of Tailings or Wastes Produced by the Extraction or Concentration of Source Material From Ores Processed Primarily for Their Source Material Content, available at http://www.nrc.gov/reading-rm/doc-collections/cfr/part040/part040-appa.html. Accessed July 2013. U.S. Nuclear Regulatory Commission, June 2003. Standard Review Plan for In Situ Leach Uranium Extraction License Applications. Final Report. NUREG-1569. Prepared by J. Lusher., U.S. Nuclear Regulatory Commission, NRC ADAMS Accession Number: ML032250177. U.S. Nuclear Regulatory Commission, March, 2012a. Stages of the Nuclear Fuel Cycle. http://www.nrc.gov/materials/fuel-cycle-fac/stages-fuel-cycle.html. Accessed July 2012. U.S. Nuclear Waste Technical Review Board, 2010. http://www.nwtrb.gov/facts/factsheets.html U.S. Small Business Administration, March 2012. Table of Small Business Size Standards. http://www.sba.gov/content/small-business-size-standards University of Chicago, 2004. The Economic Future of Nuclear Power. Uranerz Energy Corp  -  2013 Anural Report. http://www.uranerz.com/i/pdf/FS_2013_Dec_31%20.pdf  Uranium Energy Corp.  -  2013 Annual Report. http://www.sec.gov/Archives/edgar/data/1334933/000106299313005003/form10k.htm  Uranium One  -  2013 Annual Report. http://www.uranium1.com/index.php/en/investor/financial-reports-and-filings/annual-reports  Uranium Resources Inc., 2013 10-K Annual Report. http://urre.client.shareholder.com/ Ur-Energy  -  2013 Annual Report. http://www.ur-energy.com/storage/investor-info/financial-reports/2013/v369199_UR-ENERGY%20INC%20FORM%2010-K%20Clean.pdf  USEC, Inc. website information about contracts for Russian uranium. http://www.usec.com/russian-contract. Accessed 2014. Ux Weekly, 2004, Supply Elasticity of Uranium.Ux Weekly. Volume 18, Issue 39, September 27, 2004. Ux Weekly, 2013. Spot Price of Uranium, July 2013. Available at http://www.uxc.com/review/uxc_Prices.aspx White House Office of Management and Budget. September 17, 2003. Circular A-4. Regulatory Analysis. http://www.whitehouse.gov/omb/circulars_a004_a-4   World Nuclear Association, 2012a. ISL Mining of Uranium. http://www.world-nuclear.org/info/inf27.html World Nuclear Association, 2012b. World Uranium Mining. http://www.world-nuclear.org/info/inf23.html World Nuclear Association, 2012c. How uranium ore is made into nuclear fuel. http://www.world-nuclear.org/Nuclear-Basics/How-is-uranium-ore-made-into-nuclear-fuel-/. Accessed August 2012. World Nuclear Association, 2012d. Uranium Enrichment. http://www.world-nuclear.org/info/inf28.html World Nuclear Association, 2013. Military Warheads as a Source of Nuclear Fuel. Available at: http://www.world-nuclear.org/info/Nuclear-Fuel-Cycle/Uranium-Resources/Military-Warheads-as-a-Source-of-Nuclear-Fuel/. Accessed August 2013. World Nuclear News, 2011. USEC deals with TENEX to supply uranium. http://www.world-nuclear-news.org/C-Tenex_to_supply_enriched_uranium_to_USEC-2403114.html Young, R.A., 2005. Determining the Economic Value of Water: Concepts and Method. Washington, DC: Resources for the Future Press. Zheng, C. and P.P. Wang, 1999. MT3DMS: A modular three-dimensional multispecies model for simulation of advection, dispersion and chemical reactions of contaminants in groundwater systems; Documentation and User's Guide, Contract Report SERDP-99-1, U.S. Army Engineer Research and Development Center, Vicksburg, MS.

Appendix A: Unit Costs for Wells and Borings Unit costs were compiled for both wells and geotechnical borings. The number of wells and borings varied between the groundwater monitoring scenarios. The following is a summary of the unit costs used in the cost analysis. A.1	Mine Unit Wells The well types considered in the conceptual mine unit (CMU) models developed for the groundwater monitoring scenarios evaluated include: Injection wells Extraction wells Perimeter monitoring wells, Excursion monitoring wells in the overlying and underlying aquifers Additional well types considered for some scenarios included: Down-gradient ore zone monitoring wells, Remediation wells The total depths of these wells were based on the hydrogeology of the example mine unit from the Highland site in Wyoming. Table A-1 below summarizes the well depths of overlying and underlying monitoring wells and also the production wells (Michel and Hoffman, 1991). The average depth for each well zone (i.e., ore zone, overlying aquifer, and underlying aquifer) was used to calculate the unit costs. EPA (2012b) previously estimated the cost per foot (ft) for well construction. This was assumed to include costs for well materials (casing, well screen, caps, etc.), mobilization of drill rig and support trucks, drilling time, and surface completion (materials and labor). Range of costs for well construction was from $9 to $32 per foot. Higher costs per foot were typically for shallower wells. Based on documentation provided by EPA a cost of $30 per foot was assumed for any well 500-ft or deeper. Since the wells at the Highland site, on which the CMU model was based, are in the 500-foot depth range, the unit cost of $30 per foot was chosen all well types considered in the groundwater monitoring and remediation scenarios. Costs of production wells were also used for other ore zone wells (i.e., ore zone monitoring wells and remediation wells). Table A-1.	Depth of Selected Wells and Average Unit Cost

Overlying Wells

Underlying Wells

Injection/Extraction Wells

Total Depth Well Cost

Total Depth Well Cost

Total Depth Well Cost

410.4 $12,312

620.5 $18,615

635 $19,050

519.1 $15,573

658 $19,740

624 $18,720

534 $16,020

669 $20,070

559.3 $16,779

435 $13,050

681.3 $20,439

562 $16,860

484 $14,520

689.45 $20,684

597 $17,910

426 $12,780

682 $20,460

602 $18,060

510 $15,300

670 $20,100

618 $18,540

550 $16,500

650 $19,500

596 $17,880

424.5 $12,735

651 $19,530

589 $17,670

540 $16,200

676.8 $20,304

600.5 $18,015

520 $15,600

664.1 $19,923

600 $18,000

545 $16,350

669.6 $20,088

610.5 $18,315

450 $13,500

660 $19,800

602.5 $18,075

668 $20,040

584 $17,520

690 $20,700

596.5 $17,895

594 $17,820

600.4 $18,012

589.9 $17,697

592 $17,760

595 $17,850

600 $18,000

597.1 $17,913

602.5 $18,075

592 $17,760

597 $17,910

612 $18,360

614.6 $18,438

621.3 $18,639

618 $18,540                                                                     (continued)                                                                                Table A-1.	Depth of Selected Wells and Average Unit Cost (continued)

Overlying Wells

Underlying Wells

Injection/Extraction Wells

Total Depth Well Cost

Total Depth Well Cost

Total Depth Well Cost

614 $18,420

625 $18,750

604 $18,120

650 $19,500

645 $19,350

600 $18,000

601 $18,030

571.5 $17,145

588 $17,640

629.6 $18,888

595 $17,850

607 $18,210

586 $17,580

593 $17,790

599.3 $17,979

581.7 $17,451

537 $16,110

585.4 $17,562

592.4 $17,772

612.8 $18,384

631.8 $18,954

602.55 $18,077

591.6 $17,748

591 $17,730

592.5 $17,775

557 $16,710 MAX= 550 $16,500

690 $20,700

650 $19,500 MIN= 410 $12,312

621 $18,615

537 $16,110 MEDIAN= 510 $15,300

669 $20,070

599.3 $17,979 AVERAGE= 488 $14,649

660 $19,795

600 $17,993

A.2	Geotechnical Borings Costing information available from the U.S. DOE (2013) for geotechnical boring drilled for characterizing the geochemistry for geothermal energy development in the western United States was used as a guide for estimating corehole costs. However, due to the way the DOE costs were presented and limited time, the estimated costs for geotechnical borings was also based on experience and best professional judgment. The costs of a geotechnical boring is related to the corehole depth, penetration rate expected, drilling method and technology requirements, the number of samples, type of samples taken and the sample method; and there are also regional factors that control costs for drilling and construction services (e.g., variation in licensing and permitting requirements). Boring costs were only assumed applicable for geochemical modeling. Drilling time was assumed to be one day per corehole with a maximum drilling depth of 650-feet which is the total average depth assumed for the underlying non-exempt aquifer in the CMU. Composite sampling of selective zones in each corehole was assumed resulting in 2 samples per corehole, on average, sent to the laboratory for analysis. Costs for core analysis and logging were also included. A summary of the boring costs assumptions and the total costs for the boreholes is provided in Table A-2. Table A-2.	Summary of Well and Borehole Costs Assumed for Modeled Scenarios Well Types Unit Cost ($/well; $/core; $/day) CMU Well Totals and Costs

CP 2011$ 30-yr  2011$ 30-yr with Geochem 2011$ OZ-PW $17,993 26                                                                        $467,805 26                                                                        $467,805                                       26                                                                        $467,805 OZ-IW $17,993 166                                                                      $2,986,755 166                                                                      $2,986,755                                       166                                                                      $2,986,755 OZ-EW $17,993 77                                                                      $1,385,423 77                                                                      $1,385,423                                       77                                                                      $1,385,423 OZ-MW $17,993 0                                                                              $0 0                                                                              $0                                       10                                                                        $179,925 OW $14,649 5                                                                         $73,246 10                                                                        $146,492                                       10                                                                        $146,492 UW $19,795 10                                                                        $197,950 20                                                                        $395,900                                       20                                                                        $395,900   Well Totals: 284                                                                      $5,111,179 299                                                                      $5,382,375                                       309                                                                      $5,562,300 Core Hole $11,316.50  0                                                                          $0.00  0                                                                          $0.00                                      8*650ft                                                                     $90,532.00  Core Analysis $400.00  0                                                                          $0.00  0                                                                          $0.00                                         8                                                                      $3,200.00  Lab Analysis $400.00  0                                                                          $0.00  0                                                                          $0.00                                         8                                                                      $3,200.00    Core Totals: 0                                                                          $0.00  0                                                                          $0.00                                                                                $96,932.00  CP = current practice A.3	References Michel, T.G. and G. Hoffman, July 1991. E-Field 50 Sand Mine Unit Hydrology Test, Highland Uranium Project, Power Resources, Inc.; Report for WDEQ/LQD Permit Number 603, U. S. Nuclear Regulatory Commission Docket Number 40-8857, SUA-1511; Report by Power Resources, Inc. and Hydro-Engineering; September 1990, revised July 1991. U.S. Department of Energy, 2013. Cost and Time Metric Tool (Web Application); National Renewable Energy Laboratory; Internet resource: http://en.openei.org/wiki/Exploration_Cost_and_Time_Metric U.S. EPA, March 26, 2012b. Data collected (WA 2-04, Task B) and provided by EPA.

Appendix B: Summary of Unit Costs for Sampling and Analysis Unit costs were determined for the collection and analysis of a groundwater sample. These unit costs were then used for estimating total sampling and analysis costs for each of the groundwater monitoring scenarios evaluated. Groundwater sampling and analysis costs are summarized for each scenario in Section 3 of the report. B.1	Analysis Costs The total laboratory costs are dependent upon the number of parameters that are analyzed. EPA recognizes that analytical costs are site specific since the list of parameters required for monitoring are a function of the geochemistry of the aquifer units being sampled, as well as operational and regulatory requirements. In general, analytes may be required for analysis based on EPA or state regulation, to identify excursions, to monitor the condition of the lixiviant, and to characterize and model the pre and post-mining geochemistry (U.S. EPA, 2012a). The groundwater monitoring scenario cost models have assumed full lists of applicable analytes, and no assumptions were made that would serve to reduce a list of parameters and analytes (e.g., based on the Highlands site geochemistry and CMU model) that might be sampled due to an assumed monitoring requirement (i.e., state, EPA NRC, etc.). The lists of parameters and analytes were originally compiled from 4 different sources -- including EPA, NRC, TCEQ, and WDEQ -- as seen in Table B-1. A unit cost was developed to estimate the cost of analyzing the full suite of 56 parameters, as well as for various subsets, including the EPA specified 33 parameters, the 35 parameters from the NRC's ISL Standard Review Plan, and the state specified parameters. EPA collected costs to perform the specific analyses required from 12 actual analytical laboratories (TDSHS, 2007; Pace, 2009; BVNA, 2010; NDHHS, 2010; ELI, 2011; CCAL, 2012; ML, 2013; ELI, 2013; SARA, 2012; ACTI, 2005; EPA, 2012b). The average, low, median, and high analytical costs for each analyte are shown in Table B-1. Average costs were only used in the analysis of the groundwater monitoring scenarios; however, the other costs are provided for comparison. Table B-1.	Analysis Costs for Analytes Generally Required in ISR Groundwater Monitoring Programs (2011$) Species Requirements by Analyte Group Analysis Cost (sample[-1])