~DENVER, CO OFFICE~Uranium Resources, Inc.

6950 S. Potomac Street, Suite 300U IUanium Resources, Inc, Centennial, CO 80112

Tel: (303) 531-0470Fax: (303) 531-0519

November 27, 2015

VIA FEDERAL EXPRESS DELIVERY

Mr. Daniel Gillen, ChiefFuel Cycle Facilities BranchDivision of Fuel Cycle Safety and SafeguardsOffice of Nuclear Materials Safety and SafeguardsNuclear Regulatory CommissionMail Stop T-8F4211555 Rockville PikeTwo White Flint NorthRockville, MD 20852-273 8

SUBJECT: Ilydro Resources, Inc.'s Crownpoint Uranium Project; Application forApproval of Indirect Transfer of Control of NRC Materials License No.SUA-1580 (Docket No. 040-08968)

Dear Mr. Gillen:

Uranium Resources, Inc., a Delaware corporation ("URI" or "the Company"), on behalf of itswholly-owned subsidiary Hydro Resources, Inc. ("the Licensee"), and Laramide Resources Ltd.("Laramide"), a corporation organized under the Canada Business Corporations Act, herebyrequest written consent by the U.S. Nuclear Regulatory Commission ("NRC") for the proposedindirect transfer of control of the above-listed NRC source material license, License No. SUA-1580 (the "License"). Attachment 1 provides the basis for this request. On November 9, 2015,the Company entered into a Letter of Intent ("LOI") with Laramide for the sale of the Licensee,which holds certain properties in New Mexico, to Laramide (the "Proposed Transaction"). Apress release detailing the Proposed Transaction was included as an exhibit to the Company'sForm 8-K filed with the Securities and Exchange Commission ("SEC") on November 13, 2015.The closing for the Proposed Transaction that would result in the indirect change in control overthe Licensee is set to occur upon the receipt of NRC regulatory approval (among other closingconditions). Accordingly, the parties respectfully request the NRC's expedited review andwritten consent to the proposed indirect transfer no later than January 22, 2016, and sooner, ifpossible, in order to permit the companies to take the necessary steps to close as soon as possibleand in any event by March 31, 2016.

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URI is a uranium exploration, development and production company. URI was organized in1977 to acquire and develop uranium projects in South Texas using the in-situ recovery ("ISR")process. The Company has historically produced uranium by ISR methods in the State of Texaswhere it currently has ISR projects and two Agreement State-licensed processing facilities. Italso has approximately 190,000 acres of mineral holdings in the Grants Mineral Belt of the Stateof New Mexico and 17,000 acres in the South Texas uranium province, a portion of which it willsell pursuant to the Proposed Transaction.

The Company, through the Licensee, possesses NRC Materials License SUA- 1580 for theCrownpoint Uranium Project ("CUP"), which includes the Crownpoint, Unit 1, and ChurchRock uranium recovery and processing facilities in McKinley County, New Mexico(collectively, the "CUP facilities"). None of URI's properties, including the CUP facilitieslicensed to the Licensee, are currently in production, and the CUP facilities have never beenoperational. The License is currently in timely renewal before the NRC as a result of thesubmittal of a timely license renewal application. More information on the Company isavailable at http://xvww.uraniumresources.com.

Laramide is a Canadian company organized under the Canada Business Corporations Act. It isengaged in the exploration and development of high-quality uranium assets based in Australiaand the United States. The Company is co-listed on the Toronto Stock Exchange (TSX) and theAustralian Securities Exchange (ASX) under the symbol "LAM." Laramide provides investorswith exposure to uranium assets through its portfolio of projects chosen for their productionpotential and location in safe and politically stable jurisdictions, including Westmoreland inAustralia and two development stage assets, La Sal (Utah) and La Jara Mesa (New Mexico), inthe United States. Within the portfolio are also joint ventures, farm-in arrangements, strategicequity positions and royalty participation in uranium development and exploration companiesthat provide additional diversification. Laramide's flagship, the Westmoreland UraniumProject, is located in Queensland, Australia, adjacent to the Northern Territory border.Laramide's wholly owned subsidiary, Tackle Resources Pty Ltd, owns 100% of Westmoreland,and continues to advance the project through drilling programs, updated resource estimates,environmental studies and metallurgical studies. More information on Laramide is available atwww.laramide.com.

As noted above, Laramide is a Canadian company engaged in the exploration and developmentof uranium assets based in Australia and the United States. Laramide is a "known entity" in theUnited States. Its wholly-owned subsidiary, Laramide La Sal, Inc., holds a number of licensesand permits in the United States, including Bureau of Land Management ("BLM") Permit No.DOI-BLM-UT-Y010-201 1-0162-BA. See Attachment 2 for supporting documentation. Belowis the contact information for the BLM office that administers the permit:

United States Department of the InteriorBureau of Land ManagementMoab Field Office82 East DogwoodMoab, Utah 84532Phone: (435) 250-2100

Fax: (435) 259-2148

Under the Proposed Transaction, Laramide will acquire 100% of the common shares in theLicensee from URI. When completed, the transaction will result in an indirect transfer ofcontrol of the License through the change in the Licensee's parent company from URI toLaramcide.

Importantly, the proposed indirect transfer of control would not result in any changes to theLicensee's name, organization, or NRC-licensed activities. Accordingly, the parties request thatthe NRC consent to the proposed indirect transfer of control as being in accordance withSection 184 of the ABA and 10 C.F.R. § 40.46. As a result of the transaction, the Licensee willrequire an administrative amendment to the License to reflect the Licensee's new address:62329 North Star Drive, Montrose, CO 81403. However, for business purposes, allcommunications should go to: Hydro Resources, Inc. d/o Laramide Resources Ltd., TheExchange Tower, 130 King Street West, Suite 3680, Box 99, Toronto, ON M5X IB1. Thisaddress is also the current address of Laramide's head office. A license amendment applicationto reflect the new business address change is attached. See Attachment 3.

We respectfully request that the NRC review this application and issue its consent to this indirecttransfer in an expedited manner, by January 22, 2016 if possible, in order to permit the parties tothe Proposed Transaction to take the necessary steps to close as soon as possible and in any eventby March 31, 2016.

If you have any questions or need additional information, please contact Daniel F. Stenger,counsel for URI, of Hogan Lovells US LLP, at (202) 637-5691 or by e-mail atdaniel.stenger~hoganlovells.com. Please include John Jacus, counsel for Laramide, of DavisGraham & Stubbs LLP, at (303) 892-7305, e-mail at john.jacus@dgslaw.com, on any written orelectronic communications regarding this request for indirect transfer approval.

Enclosures: Attachment 1, Application for Approval of Indirect Transfer of Control of NRCMaterials License No. SUA- 1580

Attachment 2, "Known Entity" Supporting Documents

Attachment 3, License Amendment Application

cc: Ron Linton, NRC Project ManagerDaniel Stenger, Hogan Lovells US LLPJohn Jacus, Davis, Graham & Stubbs LLP

I declare under penalty of perjury under the laws of the United States of America that the HydroResources, Inc.'s Crownpoint Uranium Project; Application for Approval of Indirect Transfer ofControl of NRC Materials License No. SUA-1 580 (Docket No. 040-08968) is true and correct.

Executed on November 23, 2015

Christopher M. JonesPresident and CEOUranium Resources, Inc.6950 South Potomac St., Suite 300Centennial, CO 80112

[HRI - Application for Indirect Transfer of NRC License]

I declare under penalty of perjury under the laws of the United States of America that the HydroResources, Inc.'s Crownpoint Uranium Project; Application for Approval of Indirect Transfer ofControl of NRC Materials License No. SUA-1580 (Docket No. 040-08968) is true and correct.

Executed on November 23, 2015

Marc HendersonPresident and CEOLaramide Resources Ltd.The Exchange Tower130 King Street WestSuite 3680, Box 99Toronto, Ontario M5X 1B11Canada

[HRI - Application for Indirect Transfer of NRC License]

Attachment 1

Application for Approval of IndirectTransfer of Control of NRC Materials License No. SUJA-1580

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This information is submitted consistent with NUJREG- 1556, Vol. 15, Consolidated GuidanceAbout Materials Licenses: Program-Specific Guidance About Changes of Control and AboutBankruptcy Involving Byproduct, Source, or Special Nuclear Materials Licenses, at Section 5.1through 5.6.

SECTION 5.1 DESCRIPTION OF TRANSACTION

1. A complete clear description of the transaction, including any transfer of stocksor assets, mergers, etc., so that legal counsel is able, when necessary, todifferentiate between name changes and changes of ownership.

The indirect transfer of control would occur as a result of a proposed transaction under whichUranium Resources, Inc. ("URI" or "the Company"), a Delaware corporation, will transfer100% of the common shares in its wholly-owned subsidiary Hydro Resources, Inc. ("theLicensee"), to Laramide Resources Ltd. ("Laramide"), a Canadian company, and Laramide willacquire full ownership of the Licensee (the "Proposed Transaction"). The Licensee holds NRCMaterials License No. SUA-1 580 (the "License"). On November 9, 2015, the Company enteredinto a Letter of Intent ("LOL") with Laramide for the sale of the Licensee, which holds certainproperties in New Mexico, to Laramide (the "Proposed Transaction"). A press release detailingthe Proposed Transaction was included as an exhibit to the Company's Form 8-K filed with theSecurities and Exchange Commission ("SEC") on November 13, 2015. The Company willreceive the following from Laramide at closing: (i) cash in the amount of $5,250,000; (ii) a notereceivable in the amount of $7,250,000 (the "Note") payable in three equal installments over thenext three years; and (iii) the Licensee will retain any liabilities related to reclamation andremediation on the properties owned by Licensee. The first installment payment under the Noteand a portion of the Interest on the Note are convertible to shares of Laramide at the option ofURI. Should URI own more than 10% of Laramide's outstanding common shares, URI shallhave the right to appoint one director to Laramide's board. The Company and Laramide willalso enter into an agreement granting URI an option to purchase Laramide's interest in its La Salproject in Utah through June 15, 2017 for US$4.0 million. If URI exercises that option, theprincipal amount payment under the Note will be reduced by $4,000,000.

If completed, the transaction would result in an indirect transfer of the License through thechange in the Licensee's parent company from URI to Laramide.

Importantly, the proposed indirect transfer of control would not result in any changes to theLicensee's name, organization, or NRC-licensed activities. As a result of the transaction, theLicensee will require an administrative amendment to the License to reflect the Licensee's newaddress: 62329 North Star Drive, Montrose, CO 81403. However, for business purposes, allcommunications should go to: Hydro Resources, Inc. d/o Laramide Resources Ltd., TheExchange Tower, 130 King Street West, Suite 3680, Box 99, Toronto, ON M5X IB1. Thisaddress is also the current address of Laramide's head office. A license amendment applicationto reflect the new business address change is attached. See Attachment 3.

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2. The new name of the licensed organization. If there is no change, the licenseeshould so state.

There will be no change in the name of the Licensee in connection with the ProposedTransaction.

3. The new licensee contact and telephone number(s) to facilitatecommunications.

The Licensee's new contact is Marc Henderson, President and CEO of Laramide, and histelephone number is (416) 599-7363. Mr. Henderson's address is Hydro Resources, Inc. d/oLaramide Resources Ltd., The Exchange Tower, 130 King Street West, Suite 3680, Box 99,Toronto, Ontario M5X IB 1.

SECTION 5.2 CHANGES OF PERSONNEL

1. Any changes in personnel having control over licensed activities (e.g., officersof a corporation and any changes in personnel named in the license such asradiation safety officer, authorized users, or any other persons identified inprevious license applications as responsible for radiation safety or use oflicensed material). The licensee should include information concerning thequalifications, training and responsibilities of new individuals.

Following the Proposed Transaction, Laramide will control the Licensee, but there are nochanges proposed at this time in personnel having control over licensed activities under theLicense.

2. An indication of whether the transferor will remain in non-licensed businesswithout the license.

As explained in Section 5.1, as a result of the Proposed Transaction, Laramide will become thenew parent company of the Licensee. URI does not have any other NRC ISR licenses, but willremain involved in the uranium mining business. In Texas, the Texas Commission onEnvironmental Quality ("TCEQ") regulates uranium mining and issues the necessary licenseand permits. UIRI holds a radioactive material license which covers the Kingsville Dome,Rosita and Vasquez sites in Texas. Each site has a class III injection permit also issued by theTCEQ. The Rosita and Vasquez permits have both been renewed in 2014, and the Kingsvillepermit is in the renewal process. Within each area's permit, the TCEQ also issues productionarea authorizations ("PAAs"). Kingsville holds three PAAs, Rosita holds 4, and Vasquez holds2 PAAs. Each site also has class I non-hazardous injection permits for operation of wastedisposal wells on site, which are regulated by the TCEQ as well. All permits for the disposalwells are active. In addition to the required state permits, the United States EnvironmentalProtection Agency regulates the underground aquifers and requires areas with uraniummineralization to have that portion of the aquifer exempted before state mining permits areissued. The aquifer exemptions for all three Texas sites have been issued.

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SECTION 5.3 CHANGES OF LOCATION, EQUIPMENT & PROCEDURES

1. A complete description of any planned changes in organization, location,facility, equipment, or procedures (i.e., changes in operating or emergencyprocedures).

There are no planned changes in the organization, location, facility, equipment, or proceduresunder the License in connection with the Proposed Transaction.

2. A detailed description of any changes in the use, possession, location or storageof the licensed materials.

The Licensee has never operated under its NRC License, and does not currently use, possess, orstore any licensed material under the License. In any event, there are no planned changes in theuse, possession, location or storage of licensed materials under the License to occur inconnection with the Proposed Transaction.

3. Any changes in organization, location, facilities, equipment, procedures, orpersonnel that would require a license amendment even without the change ofownership.

Other than the address change for the Licensee, there are no planned changes in theorganization, location, facilities, equipment, procedures, or personnel that would require alicense amendment even without the change of ownership.

SECTION 5.4 SURVEILLANCE RECORDS

1. An indication of whether all surveillance items and records (e.g., calibrations,leak tests, surveys, inventories, and accountability requirements) will be currentat the time of transfer. A description of the status of all surveillancerequirements and records should also be provided.

The Licensee has never operated under its NRC License, and thus this section is not applicable.In any event, all items and records will remain with the Licensee.

SECTION 5.5 DECOMMISSIONING AND RELATED RECORDS TRANSFERS

1. Confirmation that all records concerning the safe and effectivedecommissioning/closure of the facility; public dose and waste disposal byrelease to sewers, incineration, radioactive material spills, and on-site burials,have been transferred to the new licensee iflicensed activities will continue atthe same location.

The Licensee has never operated under its NRC License. In any event, all suchdecommissioning and related records will remain with the Licensee.

3\U3C -0405181000016- 7159747 vl

2. A description of the status of the facility. Specifically, the presence or absenceof contamination should be documented. If contamination is present, willdecontamination occur before transfer? If not, is the transferee knowledgeableof the extent and levels of contamination and applicable decommissioningrequirements, and does the transferee agree to assume full liability for thedecontamination of the facility or site?

The Licensee has never operated under its NRC License, and so there has been nocontamination as a result of its licensed activities at the CUP facilities. In any event, theLicensee will continue to have all liability for any decontamination and decommissioningrequirements at the CUP facilities. As part of the Proposed Transaction, Licensee will retain allliabilities, including any pre-existing legacy or historical environmental liabilities, for theproperties owned by Licensee.

3. A description of any decontamination plans, including financial suretyarrangements of the transferee. This should include information about how thetransferee and transferor propose to divide the transferor's assets andresponsibility for any cleanup needed at the time of transfer.

The Licensee has never operated under its NRC License, and thus there is not currently in placean NRC-approved surety arrangement to cover the estimated costs of decommissioning,reclamation, and groundwater restoration. See License Condition 9.5. In any event, theLicensee will continue to be bound by License Condition 9.5 and the NRC requirementspertaining to decontamination plans, including financial surety arrangements.

SECTION 5.6 TRANSFEREE'S COMMITMENT TO ABIDE BY THETRANSFEROR'S COMMITMENTS

1. Confirmation that the transferee agrees to abide by all commitments andrepresentations previously made by the transferor. These include, but are not

limited to: maintaining decommissioning records; implementingdecontamination activities and decommissioning of the site; and completingcorrective actions for open inspection items and enforcement actions.

With regard to contamination o ffacilities and equipment, the transferee shouldconfirm, in writing, that it accepts full liability for the site, and should provideevidence of adequate resources to fund decommissioning; or the transferorshould provide a commitment to decontaminate the facility before the change ofcontrol or ownership.

With regard to open inspection items, etc., the transferee should confirm, inwriting, that it accepts full responsibility for open inspection items and/or anyresulting enforcement actions; or the transferee proposes alternative measures

4\DC- 040518/000•016- 7159747 vi

for meeting the requirements; or the transferor provides a commitment to closeout all such actions with NRC before license transfer.

The indirect change in control of the License resulting from the Proposed Transaction wouldnot create a new licensee and would not change the Licensee's existing commitments under theLicense.

Following the Proposed Transaction, the Licensee agrees to continue to abide by all constraints,license conditions, requirements, representations and commitments identified in and attributedto the existing License, including any decommissioning and decontamination fundingobligations. The Licensee has never operated under its NRC License, so there have been nodecontamination or decommissioning activities. The Licensee agrees to continue to accept fullresponsibility for open inspection items and any resulting enforcement action. The proposedchange in the Licensee's ultimate parent company will not affect these commitments andrepresentations.

2. Documentation that the transferor and transferee agree to the change inownership or control of the licensed material and activity, and the conditions ofthe transfer; and the transferee is made aware of all open inspection items andits responsibility for possible resulting enforcement actions.

The LOI demonstrates that, subject to its terms, if the Proposed Transaction closes, URI andLaramide have agreed to the change of ownership or control. The Proposed Transaction wouldnot create a new licensee and would not change the Licensee's existing commitments under theLicense. The Licensee is aware of and will continue to be responsible for all open inspectionitems and the Licensee will remain responsible for any possible resulting enforcement actions.

3. A commitment by the transferee to abide by all constraints, conditions,requirements, representations and commitments identified in the existinglicenses. If not, the transferee must provide a description of fits program toensure compliance with the license and regulations.

The indirect change in control resulting from the transaction would not create a new licenseeand would not change the Licensee's existing commitments under the License. Following theProposed Transaction, the Licensee agrees to continue to abide by all constraints, conditions,requirements, representations, and commitments identified in the existing License.

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Attachment 2

"Known Entity" Supporting Documents

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United States Department of the interiorBUREAU OF LAND MANAGEMENT

Moab Field Office82 East DogwoodMoab, Utah 84532

TAKE" PRmIDESINAM ERICA

3809UTU-88256(UTYOI 2)

Federal Express Tracking # 8736 7458 8431 JUl41 41;201Z'

DECISION

Laramide La Sal, Inc.Attn: Mersch WardThe Exchange Tower130 King Street West, Suite 3680 :Post Office Box 99Toronto, Ontario, Canada M5X iBi

Surface Management

PLAN OF OPERATIONS MODIFICATIONS APPROVED - CONDITIONS OFAPPROVAL REOUIRED

The modifications to the Plan of Operations for Exploration for Laramide La Sal Inc.'s La SalNo.2 Uranium Sampling Project, is hereby approved subject to conditions of approval listedbelow. Laramide La Sal Inc. (Laramide) and their contractors must conduct operations asdescribed in the Plan of Operations in accordance with the following Bureau of LandManagement (BLM) conditions of approval (COA):

Conditions of Approval:

Proponent-Committed Management and Mitigation Measures

1. Undertake accepted and standard underground technology and practices.2. Undertake reclamation action once activities have ceased, and restore post-exploration

land use.3. Comply with federal and state laws and obtain permits.

4. Use existing access roads that are designated in the Moab Field Office TravelManagement Plan.

5. Comply with federal and Utah air quality standards and maintain mobile generators to

minmilze emissions.

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i@! Q6. Use existing diversion channels to route precipitation runoff away from the portal.7. Take all solid wastie off site and have no open burning on site.8. Maintain a compact operation to minimize vegetation disturbance.9. Redistribute growth medium and seed with approved seed mix at conclusion of

operations.10. Control noxious weeds by mechanical methods or use of herbicides.I1. Ccase operations if cultural or paleontological resources are unearthed and notify BLM.12. Take all reasonable measures to prevent and suppress fires in the area of operations.13. Maintain structures, equipment and site facilities in a safe and orderly manner.14. Install gates to prevent access to portal facilities.15. Fence the vent raise to prevent access and potential injury to the public.16. Comply with MSHA regulations.

BLM Terms and Conditions of Approval

General1. Approval of this Plan of Operations (Plan) does not constitute recognition or certification

of the validity of ownership by any person named as owner herein.2. Approval of the Plan does not constitute now or in the future, recognition or certification

of the validity of any of the mining claims to which it may relate nor the mineralcharacter of the land on which it lies.

3. Changes and additions to the Plan must be submitted to the BLM Field Manager forapproval as a revised or supplemental plan. The revised or supplemental Plan must beapproved by the BLM Field Office Manager before work may begin.

4. Prior to bond release, a final inspection of the project area must be made by the operatorwith the BLM Field Manager or his designated representative as appropriate based onland status.

5. Surface disturbing activities and operations must be supervised by a company

representative knowledgeable of the design features and mitigation measures of the Plan.6. Water must be legally obtained in accordance with State water laws. '

7. The BLM Field Manager or his designated representative must be notified 48 hoursbefore any operations begin.

8. The BLM Field Manager or his designated representative must be notified whenoperations are completed and informed as to when reclamation work will begin.

9. Laramide or their contractor will notify BLM temporary cessation of operations and willsecure the site using locked closures on the portal, ventilation raise, and buildings, and bymaintaining structures, equipment, and facilities in an otherwise safe and environmentally

acceptable condition.10. Approval of this Plan of Operations does not relieve the operator of obtaining all other

necessary federal, state, or local permits/authorizations before operations begin.

2

Erosion Control and Water Quality

1. Laramide and its contractors will maintain a Spill Prevention Control andCountermeasure (SPCC) Plan as required by 40 CFR 1 12.

2. Laramide and its contractor will conduct activities to prevent erosion and sedimentation.Temporary erosion control measures may be required to prevent, control, and mitigatecrosion and sedimentation. Temporary and permanent erosion control work must be keptcurrent with ongoing operations, especially when construction occurs outside of the:.normal operating season.

3. Laramide and its contractor w~ill implement dust suppression measures including thlecovering of ore material by tarps or other means in the ore haul trucks prior to leaving thesite, and application of water and/or other approved dust suppressants on the projecthaulage road and other areas of the project area, as needed.

lFire Protection

1. Vehicles with catalytic converters will be restricted to existing roads and trails; parkingor idling will not be permitted in portions of roads or trails with taller vegetation.

2. Vehicles will have working mufflers and spark attesters. Electrical equipment must beproperly insulated.

3. Fire extinguishers and shovels will be available on site.4. Opeft burning of trash will be prohibited at the project site.

Hazardous and Solid Waste/Trash Disposal

1. Chemicals and hydrocarbon products (including used oil) will be contained andcontrolled in accordance with proposed containment measures and a Spill PreventionControl and Countermeasure (SPCC) Plan prepared pursuant to 40 CFR 112.

2. The BLM Hazardous Material Coordinator will be notified as soon as possible if an orespill occurs during ore transport or if an incident occurs resulting in the spill of a largequantity of petroleum products.

3. In accordance with 29 CFR 19 10.1200(g), Laramide and their contractor will maintain afile containing Material Safety Data Sheets (MSDS) for all cheniicals, compounds, and/or.substances which are utilized during the course of construction, mining, and reclamationoperations.

4. Approved containers will be located on site for trash disposal. Trash will be transportedto an approved land fill.

5. Any solid wastes that qualify' as low-level wastes for radiation contamination, perNuclear Regulatory Commission (NRC) guideline~s (i.e., not a product or a by-product of

3

orecexlraction or production), will be handled inaccordance with the Low-LevelRadioactive: Waste Policy Amcndmnents Act of 1985 at an NRC-approved facility.

6. Laramide will provide on-site sanitation fh~cilities tbr employees and contractors duringsite operations.

Cultural Resources

I. Laramnide and its contractors will inform their employees about Federal regulationsintended to protect cultural resources.

2. If cultural resources are uncovered during surface-disturbing activities, Laramide or itscontractors will suspend activity at the site of the discovery, and immediately notify theBLM, who would immediately arrange for a determination of significance, and ifnecessary, recommend a recovery or avoidance plan.

3. Vehicular traffic, personnel and equipment movement, and construction activitiesassociated with the La Sal No. 2 Project will be confined to the locations surveyed forcultural and paleontological resources, and to the existing roadways and/or inventoried

access routes.4. Laramide will immediately notify the BLM by telephone if human remains, funei-ary

items, sacred objects, or objects of cultural patrimony are discovered. Further, theoperator must stop activities at the discovery site until instructed how to proceed by theBLM authorized officer.

Public/Crew Safety

1. Laramide will comply with applicable state and federal regulations, related to humanhealth and safety, equipment operation and maintenance of the facilities, and grounds,including Mine Safety and Health Administration (MSHA) regulations at Title 30 CFR57.5037 and Title 30 CFR 57.5047.

2. Laramide will post signs warning the public of truck traffic next to the main access roadduring the life of the project.

3. Fencing with radiation signage will be located around the ventilation raise.4. Fencing will be installed to prevent public access to the offices and portal structures, and

keep livestock out of the surface facility.

Soil Resource Protection

1. Vehicles will be instructed to travel at slow speeds to limit disturbance to roads andcreation of dust.

2. As determined necessary by BLM, fugitive dust will be controlled by watering unpavedroads and temporary ore stockpile area.

4.

3. Laramide will be salvage and protect growth medium material during the life of theproject so such material will be available for permanent site reclamation.

Vegetation Resources Protection

1.. Laramide and its contractors will clean earth moving equipment, including both on-roadand off-road equipment to remove weed seed and soil (may contain weed seed) prior tocommencing operations on public lands within thle project area.

2. Disturbed areas in the project area will be monitored for establishment and spread ofnoxious wee•ds. Laramide will treat weed infestations as necessary and as approved by theBLM to prevent additional spread.

Wildlife Resources

1. Project activities will be conducted in compliance with applicable requirements of theendangered Species Act of 1973, as amended.

2. No harassing of wildlife is permitted, avoidance of human/wildlife interactions ispromoted, and absolutely no hunting will be allowed on the project area. .

3. During times of temporary cessation (longer than one month), the portal and ventilationraise will be closed to exclude bats from entering the mine. The preferred method forexclusion of bats from an adit or shalt is to block the portal or collar with 1-inch- diameterchicken wire.

4. Raptor management will be guided by Best Management Practices for Raptors and TheirAssociated Habitats in Utah (BLM 2008: Appendix M) and Utah Field Office Guidelinesfor Raptor Protection from Human and Land Use Disturbances (Romin and Muck 2002).If construction is scheduled between the dates of January 1 and September 31, raptorsurveys will be required prior to construction. Field surveys will be conducted asdetermined by the BLM authorized officer. Based on the result of the field survey, theauthorized officer will determine if appropriate buffers and timing limitations arenecessary.

5. In order to avoid impacts to potential nesting birds within the project area, vegetationremoval will not occur during the breeding season (most migratory birds nest fr'om May15 to July 15) unless nest surveys are conducted within a five-day window of vegetationremoval to aid in nest avoidance.

6. Laramide will install standard 4 strand fencing to wildlife limit access to the site.

Livestock Grazing

1. Laramide will install standard 4 strand fencing to prevent livestock fr'om accessing thesurface facility area. Laramide will also fence the ventilation raise for safety purposes.

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Rcclanimtion

I. The BLM will be contacted for the appropriate seed mix to be used in reclamation toensure that= it contains ethnobotanical plant species as requested by Zuni Pueblo.

2. The BLM will be contacted at least 2 working days prior to the start of pennanent siteclosure and rccl,-rnation.

3. As part of site rcclamation, Laramide and it contractors will excavate ore stockpile areasto remove radionuclide-bearing rock with values above background. The rock will eitherbe transported to the White Mesa Mill For treatment or will be returned to the mineworkings..

4. Laramide and it contractors will install appropriate erosion control devices (diversionditches, check dams, wattles, silt fences, etc.) before removal of growth medium materialand site grading. Erosion and sediment control devices will be maintained throughout thelife• of the project.

5. Laramnide will return the site to pre-exploration gamma levels, as described in AppendixD, Gammna Report of the EA.

Rock Management

I. The ore haulage contractors will comply with applicable federal and state regulations,including establishment of an Emergency Response Plan.

2. Waste rock will remain underground, during exploration activities. No surface storage ofwaste rock will be allowed unless Laranmide files a modification to the plan of operations

withl the BLM and the modification is approved.3. To document the removal of sampled material, Laramide would be required to provide•.

the BLM with copies of the scale tickets or delivery tickets from the White Mesa Mill.This would ensure no more than 20,000 tons of material would be removed from the

mine.

The rationale for this decision is based on the need for Laramide to identify and assess a valuableuranium deposit through exploration under the authority of the mining laws of the United Stateswhile ensuring that operations are conducted in a manner that will prevent unnecessary or unduedegradation as defined at 43 CFR 3089.5.

Financial Guarantee

Based on your reclamation cost estimate, the BLM review of the cost estimate, coordination withthe Utah Division of Oil, Gas 'and Mining, and consideration of the above conditions of approval,the required financial guarantee amount is hereby set at $69,341.00 for reclamation of the La SalNo. 2 Uranium Sampling Project. You must provide a financial guarantee in this amount usingone or more of the acceptable financial guarantee instruments listed under 43 CFR 3 809.555.The financial guarantee must be provided to BLM Utah State Office, Branch of Minerals, P.O.Box 45155 Salt Lake City, Utah 84145-0 155. You must not begin activities under the approved

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Plan of Operations until you receive notification from the Moab Field Office that the financialguarantee has been accepted and obligated.

Approval of a Plan of Operations by the BLM does not constitute a determination regarding thevalidity or ownership of any unpatented minling claim involved in the exploration operation.Laramide is responsible for obtaining any use rights or local, state, or federal permits, licenses,or reviews that may be required for the operation.

This decision also constitutes concurrence with Laramide's use and occupancy of public lands asdescribed in the approved Plan of Operation for exploration. Laramiide and their contractorsmust maintain compliance with the Use and Occupancy regulations at 43 CFR 3715.2, 3715.2-1,and 3715.5 throughout the duration of the approved Plan of Operations. .Concurrence by theBLM on Laramide's proposed use and occupancy is not subject to State Director Review, butmay be appealed by adversely affected parties directly to the Interior Board of Land Appeals asoutlined in enclosed BLM Form 1 842-1.

.Appeal of the Decision ;

If you do not agree and are adversely affected by this decision, you. may request that the UtahBLM State Director review this decision. If you request a State Director Review, the requestmust be received' in the Utah BLM State Office at 440 West 200 South, P.O. Box 45155, SaltLake City, Utah 84145-0155, no later than 30 calendar days after you receive or have beennotified of this decision. The request for State Director Review must be filed in accordance withthe provisions in 43 CFR 3809.805. This decision will remain in effect while the State DirectorReview is pending, unless a Stay is granted by the State Director. If you request a Stay, you havethe burden of proof to demonstrate that a Stay should be granted.

If the State Director does not make a decision on your" request for review of this decision within

21 days of receipt of the request, you should consider the request declined and you may appealthis decision to the Interior Board of Land Appeals (IBLA). You may contact the Utah BLMState Office to determine when BLM received the request for State Director Review. You have30 days from the end of the 21day period in which to file your Notice of Appeal with this officeat Moab Field Office at 82 East Dogwood', Moab, Utah 84532, which we will forward to IBLA.

If you wish to bypass• a State Director Review, this decision may be appealed directly to theIBLA in accordance with the regulations at 43 CFR 3809.801(a)(1). Your Notice of Appeal mustbe filed in this office at Moab Field Office at 82 East Dogwood, Moab, Utah, 84532, within 30days from receipt of this decision. As the appellant you have the burden of showing that 'thedecision appealed from is in error.

If you wish to file a petition pursuant to regulations• 43 CFR4.21 for a stay of the effectiveness ofthis decision during the time that your appeal is being review•ed by the IBLA, the petition for astay must accompany your Notice Appeal. Copies of the Notice of Appeal and petition for staymust also be submitted to each party named in the decision and to the Office of the Solicitor atFederal Building Rm-6201, 125 South State Street, Salt Lake City, Utah 84138, at the same time

'7

Q... N:..

the original documnents are filed in this office. if you request a stay, you have the burden ofproof to demonstrate that a stay should be granted based on the standards listed below.

Standards of Obtaining a Stay

Except as otherwise provided by law or other pertinent regulation, a petition for a stay of adecision pending appeal shall show sufficient justification based on the following standards:

1. The relative harm to the parties iftlhe stay is granted or denied;2. The likelihood of the appellant's success on the merits;3. The likelihood of immediate and irreparable harm if the stay is not granted; and4. Whether the public interest favors granting the stay.

If you have any questions, please contact Rebecca Doolittle in person at 82 East Dogwood,Moab, Utah, 84532 or by telephone at (435) 259-2141.

Isi Lisa Bryant

Field Manager

1 Enclosure1 - Form 1842-1, Information on Taking Appeals to the Interior Board of Land Appeals.

cc: Gochnour & AssociatesMunson/UDOGMAbeyta/UT923

rd:rdoolitt:06/12/2012 "

8"

United States Department of the InteriorBureau of Land Management

FINDING OF NO SIGNIFICANT IMPACTANDDECISION RECORD

DOI-BLM-UT-Y010-2011-0162-EA

June 2012

La Sal No. 2 Uranium Sampling ProjectNW 1/ Section 34, NW '4 Section 35, T.29'4 S., R.24 E.San Juan County, Utah

Bureau of Land ManagementMoab Field Office82 East DogwoodMoab, Utah 84532(435) 259-2100(435) 259-2148 FAX

Applicant/Address:

Laramide La Sal, Inc.The Exchange Tower130 King Street West, Suite 3680Post Office Box 99Toronto, Ontario, Canada M5X iBi(416) 599-7363(416) 599-4959 FAX

FINDING OF NO-SIGNIFICANT IMPACT.,AND

DECISION RECORD ..

DOI-BLM-UT-YO1O-2011-0162-EALa Sal No. 2 Uranium Sampling Project

INTRODUCTION

The Bureau of Land Management (BLM), Moab Field Office has conducted an environmental analysis(DOI-BLM-UT-Y010-2011-0162-EA) for a proposed uranium sampling project in the Lisbon ValleyUranium District near La Sal in San Juan County, Utah. The project would assess the integrity of thepast workings and conduct necessary rehabilitation, and underground exploration work would includegeologic mapping, underground drilling and perform gamma probing, geotechnicai investigative work,test mining procedures, and collection of bulk samples for metallurgical and mill compatibility studies.

The underlying need for the Proposed Action is for Laramide to explore for and assess a potentiallyvaluable deposit of uranium from unpatented mining claims under the authority of the Mining Law of1872, as amended. The lands are not withdrawn from mineral entry and therefore, are subject tolocation under the mining laws of the United.

The proposed project would include the rehabilitation of the existing decline and ventilation/escaperaise, along with the placement of temporary surface support facilities such as an office trailer, a minerchange trailer (dry), a maintenance facility, a fuel storage area, and stormwater management andexplosive storage. Approximately 5 acres would be used for the portal area, raise, and site access road.Once underground in the designatedJ mineralized zone, Laramide plans to conduct geologic mapping,longhole drilling with gamma probing, and bulk sample collection for metallurgical and millcompatibility studies. There would be no on-site mill or associated tailings facilities at the La Sal No. 2Project site, and any geologic and bulk samples would be shipped off-site for testing and analyticalwork.

For a detailed description of the proposed action, including the use of electric line power, as described

in Alternative C, the reader should refer to the attached EA. A no action alternative and two actionalternatives were analyzed in the EA.

PLAN CONFORMANCE AND CONSISTENCY

The proposed action conforms to the Moab Field Office Resource Management Plan (RMP), signedOctober 31, 2008. It is located in an area that the BLM has identified as available for mineral entry. Inaddition, on page 73 of the RMP, the BLM's stated goal for this area is to "provide opportunities for

FINDING of No Significant Impact and Decision Record 2 of 13DOI-BLM-UT-YO1O-2021-O162-EALa Sal No. 2 Uranium Sampling Project

environmentally responsible exploration and development of mineral and energy resources subject toappropriate BLM policies, laws and regulations."

FINDING OF NO SIGNIFICANT IMPACT

Based upon a review of the EA and the supporting documents, I have determined that the project isnot a major federal action and will not significantly affect the quality of the human environment,individually or cumulatively with other actions in the general area. No environmental effects meet thedefinition of significance in context or intensity as defined in 40 CRF 1508.27 and do not exceed thoseeffects described in the Moab RMP/FEIS. Therefore, an environmental impact statement Is notneeded.

This finding is based on the context and intensity of the project as described:

Context:

The La Sal No. 2 Project is a site-specific action directly involving approximately five acres of BLMadministered land that by itself does not have international, national, regional, or state-wideimportance. The project is located in a remote but easily accessible area of San Juan County, Utah,where uranium mining has occurred in the past. The project would occupy the same area HomestakeMining Company developed in the early 1980's. Bulk samples would be trucked to the White Mesamill, approximately six miles south of Blanding, Utah, approximately seventy miles south of theproposed project area. Mill production and/or maintenance operations have continued since 1980.

Intensity:

The following discussion is organized around the Ten Significance Criteria described in 40 CFR 1508.27and incorporated into resources and issues considered (includes supplemental authorities Appendix 1H-1790-1) and supplemental Instruction Memorandum, Acts, regulations and Executive Orders. Thefollowing have been considered in evaluating intensity for this proposal:

1. Impacts may be both beneficial and adverse

The environmental impacts of the Proposed Action are fully disclosed in the EA. Mitigatingmeasures to reduce impacts were incorporated into the Proposed Action. None of theenvironmental effects discussed in detail in the EA~and associated appendices are consideredsignificant, nor do the effects exceed those described in the Moab Field Office ResourceManagement Plan /FEIS (BLM 2008b).

Adverse effects include minor impacts to air quality, vegetation, soils, visual resources,recreation, and human health and safety that would occur during, the sampling project.Improvement of the access roads used would serve to control surface run-off, result in graveladditions to sections of roads, currently in poor condition. There would be a short term

FINDING of No Significant Impact and Decision Record 3 of 13DOI.BLM-UT-YO1O-2O11-0162-EALa Sal No. 2 Uranium Sampling Project

economic boost to this rural area of Utah, via the workers needed for the exploration project,and their relatively high salaries for the area. Local taxes would also be incrementally increasedfor the short term.

2. The degree to which the selected alternative will affect public health or safety.

The issue of human health and safety is analyzed in detail in the EA. Direct minor adverseeffects considered include health risks for workers and the general public from radiationhazards and transportation. The indirect effects from processing sampling ore at the WhiteMesa Mill site were also considered. These impacts are expected to be minimal based on theprotective measures described in the Proposed Action and those measures incorporated withinthe permits and licenses issued by various state and federal agencies overseeing millingoperations. The sampling project will be in compliance with MSHA regulations.'

3. Unique characteristics of the geographic area such as proximity to historic or culturalresources, park lands, prime farm lands, wetlands, wilderness, wild and scenic rivers, orecologically critical areas.

As listed in Appendix A of the EA, the following Critical Elemernts of the Human Environment willnot be affected because they are not present in the project area: Areas of CriticalEnvironmental Concern (ACEC), Prime or Unique Farmlands, Wetlands or Riparian Zones, Wildor Scenic Rivers, and Designated Wilderness or Wilderness Study Areas. Cultural resourceinventories were conducted for the Area of Potential Effect. No National Register of HistoricPlaces - eligible or otherwise significant cultural resources were found in the project area. Nohistoric properties would be affected by the sampling project.

4. The degree to which the effects on the quality of the human environment are likely to behighly controversial.

Public input regarding the sampling project has been solicited through a scoping and publicreview process initiated in April 2011. The Exploration Plan of Operations was made availableto several federal, state, and local agencies and the general public for a 30 day review andscoping period beginning May 4, 2011. As stated in Section 5.2 the BLM received one commentletter during the scoping period which helped focus detailed analysis in the EA to the followingseven air; noise; soils; water; socioeconomlcs; wildlife and geology / mineral resources.

During the Native American consultation, the BLM received 2(two) letters from tribes. The EAwas released for a 30 day public review and comment period, which ended on November 7,2011, during which the BLM received 3 letters, one from a member of the general public, onefrom an organization (Uranium Watch) and one from San Juan County Commissioners.

The comments from the general public and Uranium Watch, stated localized concern for theeffects of uranium mining, in general and the potential noise at the nearest residential

FINDING of No Significant Impact and Decision Record 4 of 13DOI-BLM-UToyO1O-2011-O162-EALa Sal No. 2 Uranium Sampling Project

property. The San Juan County Commissioners supported the project from a socioeconomicsperspective, and places the project in the context of historical uranium mining. Consultationwith Native American Tribes resulted in the addition of medicinal plants being added to thereclamation seed mixture of the site, and fencing the project to keep livestock away from thesurface facility areas.

Several changes were made to the EA as a result of public comments. These changes rangedfrom minor editorial corrections to additional discussion of environmental impacts, none ofwhich resulted in identification of significant new impacts or affected the scope of the analysis.The BLM's responses to public comments are included in the EA, in Appendix D: Comments andResponses.

The Lisbon District in Utah has a history of uranium exploration and mining. Potash mining,copper mining, and oil and gas development, also remain active in the area.

5. The degree to which the possible effects on the human environment are highly uncertain orinvolve unique or unknown risks.

The Proposed Action is not unique or unusual. Uranium exploration, mining, and ore processinghave a long history in southeast Utah and other parts of the Colorado Plateau. Theenvironmental effects of the La Sal No. 2 Project to the human environment are fully analyzedin the EA. There are no predicted effects on the human environment that are considered to behighly uncertain or involved unique or unknown risks.

6. The degree to which the action may establish a precedent for future actions with significanteffects or represents a decision in principle about a future consideration.

The Proposed Action neither establishes a precedent for future BLM actions with significanteffects nor represents a decision in principle about a future consideration.

7. Whether the action Is related to other actions with individually insignificant but cumulativelysignificant impacts - which Include connected actions regardless of land ownership.

No individually or cumulatively significant impacts were identified for the Proposed Action. Acomplete disclosure of the effects of the project is contained in Chapter 4 of the EA. The minoradverse and beneficial impacts identified for the Proposed Action, in conjunction with anyimpacts of other past, present, or reasonable foreseeable future actions will have negligiblecumulative impacts on the human environment.

8. The degree to which the action may adversely affect districts, sites, highways, structures, or

other objects listed in or eligible for listing in the National Register of Historic Places or maycause loss or destruction or significant scientific, cultural, or historical resources

FINDING of No Significant Impact and Decision Record 5 of 13DOI-BLM-UT-YO10-2011-0162-EALa Sal No. 2 Uranium Sampling Project

Intensive cultural resource inventories were conducted for the project area. No HistoricProperties (NRHP eligible sites) were found in the project area. The Utah State HistoricPreservation Office was consulted pursuant to Section 106 of the National Historic PreservationAct, and that office concurred with the BLM's findings that no historic properties would beaffected. Consultations were also conducted with 15 tribal entities in order to identify anyconcerns related to traditional cultural properties or sacred: sites. Specific concerns to thetribes were addressed in the EA and Finding of No Significant Impact / Decision Record. Thoseinclude adding medicinal plants to the reclamation seed mixture, and fencing a portion of thesurface facility areas to exclude livestock entry.

The project will not adversely affect districts, sites, highways, structures, or other objects listedin or eligible for listing in the National Register of Historic Places, nor will it cause loss ordestruction of significant scientific, cultural, or historical resources.

9. The degree to which the action may adversely affect an endangered or threatened species orits habitat that has been determined to be critical under the Endangered Species Act of 1973,or the degree to which the action may adversely affect: 1) a proposed to be listed endangeredor threatened species or its habitat, or 2) a species on BLM's sensitive species list.

The proposed project area does not include critical habitat as designated by the U.S. Fish andWildlife Service (USFWS) for any listed species. The area is not suitable for Mexican SpottedOwl occupancy because the primary constituent elements are lacking.

This project would have no effect on Mexican Spotted Owls and their habitats. Consultationwith the USF&W Service is not required since there are no known threatened or endangeredspecies and associated habitat within or near the project area, and listed species would not beaffected by the Proposed Action.

See Section 1.8.2 Special Status Wildlife Species, for a complete discussion of wildlife specieseliminated from detailed analysis. In summary, the Southwestern willow flycatchers, burrowingowls, and the Gunnison prairie dog would have no negative impacts from the proposed project.Several species of bats are analyzed in the EA, and project activities are not expected to reducebat populations in the area. See Wildlife Section 4.7.2 Alternative B - Proposed Action.

10O Whether the action threatens a violation of a federal, state, local, or tribal law, regulation orpolicy imposed for the protection of the environment, where non-federal requirement areconsistent with federal requirements.

The project does not violate any known federal, state, local, or tribal law or requirementimposed for the protection of the environment. Federal, state, local, and tribal interests weregiven the opportunity to participate in the environmental analysis process. Although severalcomments were received, none of the respondents identified a violation of applicable

FINDING of No Significant Impact and Decision Record 6 of 13DOI-BLM-UT-Y01O-2011-O162-EALa Sal No. 2 Uranium Samnpling Project

environmental laws, regulations, or other requirements. In addition, the project is consistentwith applicable land management plans, policies, and programs.

DECISION

It is my decision to authorize Laramide's Exploration Plan of Operations for the La Sal No. 2 UraniumSampling Project, as analyzed under Alternative C, in the EA. This decision is contingent upon Laramidefulfilling environmental commitments by implementing protective mitigation measures incorporatedinto the Exploration Plan of Operations and by adhering to the mitigation measures and conditions ofapproval described in the EA and this Finding of No Significant Impact Decision Record.

Authorities:

The authority for this decision is contained In the Federal Land Policy and Management Act of 1976.

Cornpliance and Monitoring:

The BLM will routinely inspect operations to verify compliance with the approved Explorations Plan ofOperations and regulations at 43 Code of Federal Regulations 3809 and 3715. The specificenvironmental protection measures set forth below describe the activities that will be monitored bythe BLM.

Proponent-Committed Management and Mitigation Measures1. Undertake accepted and standard underground technology and practices2. Undertake reclamation action once activities have ceased, and restore post-exploration land

use3. Comply with federal and state laws and obtain permits4. Use existing access roads that are designated in the Moab Field Office Travel Management Plan5. Comply with federal and ~Utah air quality standards and maintain mobile generators to minimize

emissions6. Use existing diversion channels to route precipitation runoff away from the portal7. Take all solid waste off site and have no open burning on site8. Maintain a compact operation to minimize vegetation disturbance9. Redistribute growth medium and seed with approved seed mix at conclusion of operations10. Control noxious weeds by mechanical methods or use of herbicides11. Cease operations if cultural or paleontological resources are unearthed and notify BLM12. Take all reasonable measures to prevent and suppress fires In the area of operations13. Maintain structures, equipment and site facilities in a safe and orderly manner14. Install gates to prevent access to portal facilities15. Fence the vent raise to prevent access and potential injury to the public16. Comply with MSHA regulations

FINDING of No Signific¢ant Impact and Decision Record 7 of 13DOI-BLM-UT-YO1O-2011-O162-EALa Sal No. 2 Uranium Sampling Project

BLM Terms and Conditions of ApprovalThe following terms and conditions of approval are standard best management practices.

General1. Approval of this Plan of Operations (Plan) does not constitute recognition or certification of the

validity of ownership by any person named as owner herein.2. Approval of the Plan does not constitute now or in the future, recognition or certification of the

validity of any of the mining claims to which it may relate nor the mineral character of the landon which it lies. "

3. Changes and additions to the Plan must be submitted to the BLM Field Manager for approval asa revised or supplemental plan. The revised or supplemental Plan must be approved by theBLM Field Office Manager before work may begin. •

4. Prior to bond release, a final inspection of the project area must be made by the operator withthe BLM Field Manager or his designated representative as appropriate based on land status.

5. Surface disturbing activities and operations must be supervised by a company representativeknowledgeable of the design features and mitigation measures of the Plan.

6. Water must be legally obtained in accordance with State water laws.7. The BLM Field Manager or his designated representative must be notified 48 hours before any

operations begin.8. The BLM Field Manager or his designated representative must be notified when operations are

completed and informed as to when reclamation work will begin.9. Laramide or their contractor will notify BLM temporary cessation of operations and will secure

the site using locked closures on the portal, ventilation raise, and buildings, and by maintainingstructures, equipment, and facilities in an otherwise safe and environmentally acceptablecondition. '

10. Approval of this Plan of Operations does not relieve the operator of obtaining all othernecessary federal, state, or local permits/authorizations before operations begin.

Erosion Control and Water Quality1. Laramide and its contractors will maintain a Spill Prevention Control and Countermeasure

(SPCC) Plan as required by 40 CFR 112.2. Laramide and its contractor will conduct activities to prevent erosion and sedimentation.

Temporary erosion control measures may be required to prevent, control, and mitigate erosionand sedimentation. Temporary and permanent erosion control work must be kept current withongoing operations, especially when construction occurs outside of the normal operatingseason.

3. Laramlde and its contractor will implement dust suppression measures including the coveringof ore material by tarps or other means in the ore hlaul trucks prior to leaving the site, andapplication of water and/or other approved dust suppressants on the project haulage road andother areas of the project area, as needed.

FINDING of No Significant Impact and Decision Record 8 of 13DOI-BLM-UT-YO1O-2011-O162-EALa Sal No. 2 Uranium Sampling Project

Fire Protection1. Vehicles with catalytic converters will be restricted to existing roads and trails; parking or Idling

will not be permitted in portions of roads or trails with taller vegetation.2. Vehicles will have working mufflers and spark arresters. Electrical equipment must be properly

insulated.3. Fire extinguishers and shovels will be available on site.4. Open burning of trash will be prohibited at the project site.

Hazardous and Solid Waste/Trash Disposal1. Chemicals and hydrocarbon products (including used oil) will be contained and controlled in

accordance with proposed containment measures and a Spill Prevention Control andCountermeasure (SPCC) Plan prepared pursuant to 40 CFR 112.

2. The BLM Hazardous Material Coordinator will be notified as soon as possible if an ore spilloccurs during ore transport or if an incident occurs resulting in the spill of a large quantity ofpetroleum products.

3. In accordance with 29 CFR 1910.1200(g), Laramide and their contractor will maintain a filecontaining Material Safety Data Sheets (MSDS) for~all chemicals, compounds, and/orsubstances which are utilized during the course of construction, mining, and reclamationoperations.

4. Approved containers will be located on site for trash disposal. Trash will be transported to anapproved land fill.

5. Any solid wastes that qualify as low-level wastes for radiation contamination, per NuclearRegulatory Commission (NRC) guidelines (I.e., not a product or a by-product of ore extractionor production), will be handled in accordance with the Low-Level Radioactive Waste PolicyAmendments Act of 1985 at an NRC-approved facility.

6. Laramlde will provide on-site sanitation facilities for employees and contractors during siteoperations.

Cultural Resources1. Laramide and its contractors will inform their employees about Federal regulations intended to

protect cultural resources.2. If cultural resources are uncovered during surface-disturbing activities, Laramide or its

contractors will suspend activity at the site of the discovery, and immediately notify the BLM,who would immediately arrange for a determination of significance, and If necessary,recommend a recovery or avoidance plan.

3. Vehicular traffic,personnel and equipment movement, and construction activities associatedwith the La Sal No. 2 Project will be confined to the locations surveyed for cultural andpaleontological resources, and to the existing roadways and/or inventoried access routes.

4. Laramide will immediately notify the BLM by telephone if human remains, funerary items,sacred objects, or objects of cultural patrimony are discovered. Further, the operator must stopactivities at the discovery site until instructed how to proceed by the BLM authorized officer.

FINDING of No Significant Impact and Derision Record 9 of 13DOI-BLM-UT-YO1o-2011-a162-EALa sal No. 2 Uranium Sampling Project

Public/Crew Safety1. Laramide will comply with applicable state and federal regulations, related to human health

and safety, equipment operation and maintenance of the facilities, and grounds, including MineSafety and Health Administration (MSHA) regulations at Title 30 CFR 57.5037 and Title 30 CFR57.5047.

2. Laramide will post signs warning the public of truck traffic next to the main access road duringthe life of the project.

3. Fencing with radiation signage will be located around the ventilation raise.4. Fencing will be installed to prevent public access to the offices and portal structures, and keep

livestock out of the surface facility.

Soil Resource Protection1. Vehicles will be instructed to travel at slow speeds to limit disturbance to roads and creation of

dust.2. As determined necessary by BLM, fugitive dust will be controlled by watering unpaved roads

and temporary ore stockpile area.3. Laramlde will be salvage and protect growth medium material during the life of the project so

such material will be available for permanent site reclamation.

Vegetation Resources Protection1. Laramide and its contractors will clean earth moving equipment, including both on-road and

off-road equipment to remove weed seed and soil (may contain weed seed) prior tocommencing operations on public lands within the project area.

2. Disturbed areas in the project area will be monitored for establishment and spread of noxiousweeds. Laramide will treat weed infestations as necessary and as approved by the BLM toprevent additional spread.

Wildlife Resources1. Project activities will be conducted in compliance with applicable requirements of the

endangered Species Act of 1973, as amended.2. No harassing of wildlife is permitted, avoidance of human / wildlife interactions is promoted,

and absolutely no hunting will be allowed on the project area.3. During times of temporary cessation (longer than one month), the portal and ventilation raise

will be closed to exclude bats from entering the mine. The preferred method for exclusion ofbats from an adit or shaft is to block the portal or collar with 1-inch- diameter chicken wire.

4. Raptor management will be guided by Best Management Practices for Raptors and TheirAssociated Habitats in Utah (BIM 2008b: Appendix M) and Utah Field Office Guidelines forRaptor Protection from Human and Land Use Disturbances (Romin and M uck 2002). Ifconstruction is scheduled between the dates of January 1 and September 31, raptor surveys willbe required prior to construction. Field surveys will be conducted as determined by the BLMauthorized officer. Based on the result of the field survey, the authorized officer will determineif appropriate buffers and timing limitations are necessary.

FINDING of No Significant Impact and Decision Record 10 of 13DOI-BLM-UT-Y010-2012.-O162-EALa Sal No. 2 Uranium Sampling Project

5. In order to avoid impacts to potential nesting birds within the project area, vegetation removalwill not occur during the breeding season (most migratory birds nest from May 15 to July 15)unless nest surveys are conducted within a five-day window of vegetation removal to aid innest avoidance.

6. Laramide will install standard 4 strand fencing to wildlife limit access to the site.

Livestock Grazing

1. Laramide will install standard 4 strand fencing to prevent livestock from accessing the surfacefacility area. Laramide will also fence the ventilation raise for safety purposes.

Reclamation1. The BLM will be contacted for the appropriate seed mix to be used in reclamation to ensure

that it contains ethnobotanical plant species as requested by Zuni Pueblo.2. The BLM will be contacted at least 2 working days prior to the start of permanent site closure

and reclamation.3. As part of site reclamation, Laramide and it contractors will excavate ore stockpile areas to

remove radionuclide-bearing rock with values above background. The rock will either betransported to the White Mesa Mill for treatment or will be returned to the mine workings.

4. Laramide and it contractors will install appropriate erosion control devices (diversion ditches,check dams, wattles, silt fences, etc.) before removal of growth medium material and sitegrading. Erosion and sediment control devices will be maintained throughout the life of theproject.

5. Laramide will return the site to pre-exploration gamma levels, as described in Appendix D,Gamma Report of the EA.

Rock Management1. The ore haulage contractors will comply with applicable federal and state regulations, including

establishment of an Emergency Response Plan.2. Waste rock will remain underground, during exploration activities. No surface storage of waste

rock will be allowed unless Laramide files a modification to the plan of operations with the BIMand the modification is approved.

3. To document the removal of sampled material, Laramide would be required to provide the BIMwith copies of the scale tickets or delivery tickets from the White Mesa Mill. This would ensureno more than 20,000 tons of material would be removed from the mine.

Alternatives Considered:

The EA considered three alternatives: No Action; Proposed Action; and Proposed Action with LineElectric Power. The No Action Alternative was not selected because the No Action Alternative does notmeet the purpose and need for this project. According to 43 CFR 3809.411(d)(3), Laramide has a validand existing right to explore the uranium resource if done so in an environmentally responsiblemanner. The environmental analysis documented in the EA shows that both action alternatives would

FINDING of No Significant Impact and Decision Record 11 of 13DOI-BLM-UT-YO10-2011-O162-EALa Sal No. 2 Uranium Sampling Project

cause only minor environmental impacts and would not cause unnecessary or undue degradation ofpublic lands, thereby precluding the need to select the No Action Alternative.

Rationale for Decision:

The Proposed Action with Line Electric Power Is in conformance with the management decision in theMoab RMP, approved in October 2008. Approval of the Proposed Action with Line Electric Power, withconditions of approval would allow Laramide to conduct underground uranium sampling under theauthority of the of the mining laws of the United States while ensuring that operations are conductedin a manner that will prevent undue and unnecessary degradation as defined at 43 CFR 3809.5. Theimpacts to air quality impacts and noise are minimized. Diesel generators can be used as back upgeneration, and until the line electric service is installed, or in the case of an emergency when lineelectric service is not available. For the majority of the time, there would be no diesel emissions, andappurtenant noise from the Proposed Action two diesel generators.

The BLM has determined that the Laramide's sampling project will not cause unnecessary or undue

degradation of public lands for the following reasons:

* Adherence to the approved Mining Plan of Operations for exploration would meet the performancestandards at 43 CFR 3809.420.

* Operations are reasonably incident to prospecting, mining, or processing operations as defined at 43CFR 37 15.0-5.

* Based on the environmental analysis as documented in the EA, Laramide's sampling project withrequired mitigation and conditions of approval would have minor impacts on the human environment.

Public scoping for this EA began when the BLM posted the proposal on its Environmental NotificationBulletin Board (ENBB) on April 15, 2011. The Mining Plan of Operations for exploration was posted onthe Moab Field Office's website on May 2, 2011. BLM again informed the public on May 4 and 5, 2011by placing legal notices in the San Juan Record and Moab's Times Independent newspapers(respectively).

A 30-day comment period for the EA was initiated on October 4, 2011 and ended on November 7,2011. The BLM met with the Navajo Nation on January 24, 2012.

All comments received during scoping for the project and public review of the Mining Plan and duringthe comment period for the EA were incorporated into the analysis of the EA.

Protest/Appeal Lanauaae:

If you do not agree and are adversely affected by this decision, you may request that the Utah BIMState Director review this decision. If you request a State Director Review, the request must be

FINDING of No Significant Impact and Decision Record 12 of 13DOI-BLM-UT-YO10-2011-O162-EALa Sal No. 2 Uranium Sampling Project

received in the Utah BLM State Office at 440 West 200 South, P.O. Box 45155, Salt Lake City, Utah84145-0155, no later than 30 calendar days after you receive or have been notified of this decision.The request for State Director Review must be filed in accordance with the provisions in 43 CFR3809.805. This decision will remain in effect while the State Director Review is pending, unless a Stay isgranted by the State Director. If you request a Stay, you have the burden of proof to demonstrate thata Stay should be granted.

If the State Director does not make a decision on your request for, review of this decision within 21days of receipt of the request, you should consider the request declined and you may appeal thisdecision to the Interior Board of Land Appeals (IBLA). You may contact- the Utah BLM State Office todetermine when BLM received the request for State Director Review. You have 30 days from the endof the 21day period in which to file your Notice of Appeal with this office at Moab Field Office at 82East Dogwood, Moab, Utah 84532, which we will forward to IBLA.

If you wish to bypass a State Director Review, this decision may be appealed directly to the IBLA inaccordance with the regulations at 43 CFR 3809.801(a)(1). Your Notice of Appeal must be filed in thisoffice at Moab Field Office at 82 East Dogwood, Moab, Utah 84532, within 30 days fromnreceipt of thisdecision. As the appellant you have the burden of showing that the decision appealed from is in error.

If you wish to file a petition pursuant to regulations 43 CFR4.21 for a stay of the effectiveness of thisdecision during the time that your appeal is being reviewed by the IBLA, the petition for a stay mustaccompany your Notice Appeal. Copies of the Notice of Appeal and petition for stay must also besubmitted to each party named in the decision and to the Offilce of the Solicitor at Federal Building Rm-6201, 125 South State Street, Salt Lake City, Utah 84138, at the same time the original documents arefiled in this office. If you request a stay, you have the burden of proof to demonstrate that a stayshould be granted based on the standards listed below.

Standards of Obtaining a StayExcept as otherwise provided by law or other pertinent regulation, a petition for a stay of a dec is0:ionpending appeal shahJ show sufficientljustification based on the following standards:

1. The relative harm to the parties if the stay is granted or denied;2. The likelihood of the appellant's success on the merits;3. Thelikelihood of immediate and irreparable harm if the stay is not granted; and4. Whether the public :interest favors granting the stay.

,~uhri'ed Offi~cerDate ... ' ...... • • •Z......

FINDING of No Significant Impact and Decision Record 13 of 13DOI-BLM-UT-YO10-20110O162-EALa Sai No. 2 Uranium Sampling Project

Attachment 3

License Amendment Application

\\DE- 708351/000420- Il06820 vl

NRC FORM 313 U.S. NUCLEAR REGULATORY COMMISSION(10-2015)10 CFR 30, 32, 33, 3435, 36, 37, 39, and 40

\'jAPPLICATION FOR MATERIALS

APPROVED BYO0MB: NO. 315040120 EXPIRES: 1213112015Estimated burden per response to comply with this mandatory coltection request: 4.3 hours. Submittal of theapplication is necessary to determine that the applicant is qualified and that adequate procedures esist toprotect the pablic health and safety. Send comments regarding burden estimate to the FOtA, Privacy, andInformation Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, 00 20555-0001,or by intemet e-mail to Infoco~lecta.Reseurce~nrc.gov, and to the Desk Officer, Office ot Information andRegalatory Affairs, NEOB-10202, (3150-0120), Office of Management and Budget, Washington, DC 20503. If ameans used to impose an information collection does not display a currently valid 0MB control namber, theNRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

INSTRUCTIONS: SEE THE APPROPRIATE LICENSE APPLICATION GUIDE FOR DETAILED INSTRUCTIONS FOR COMPLETING APPLICATION.SEND TWO COPIES OF THE ENTIRE COMPLETED APPLICATION TO THE NRC OFFICE SPECIFIED BELOW. *AMENDMENTS/RENEWALSTHAT INCREASE THE SCOPE OF THE EXISTING LICENSE TO A NEW OR HIGHER FEE CATEGORY WILL REQUIRE A FEE.

APPLICATION FOR DISTRIBUTION OF EXEMPT PRODUCTS FILE APPLICATIONS WITH:

MATERIALS SAFETY LICENSING BRANCHDIVISION OF MATERIAL SAFETY, STATE, TRIBAL AND RULEMAKING PROGRAMSOFFICE OF NUCLEAR MATERIALS SAFETY AND SAFEGUARDSU.S. NUCLEAR REGULATORY COMMISSIONWASHINGTON, DC 20555-0001

ALL OThER PERSONS FILE APPLICATIONS AS FOLLOWS:

IF YOU ARE LOCATED IN:

ALABAMA, CONNECTICUT, DELAWARE, DISTRICT OF COLUMBIA, FLORIDA, GEORGIA,KENTUCKY, MAINE, MARYLAND, MASSACHUSETTS, NEW HAMPSHIRE, NEW JERSEY,NEW YORK, NORTH CAROLINA, PENNSYLVANIA, PUERTO RICO, RHODE ISLAND, SOUTHCAROLINA, TENNESSEE, VERMONT, VIRGINIA, VIRGIN ISLANDS, OR WEST VIRGINIA,

SEND APPLICATIONS TO:

LICENSING ASSISTANCE TEAMDIVISION OF NUCLEAR MATERIALS SAFETYU.S. NUCLEAR REGULATORY COMMISSION, REGION I2100 RENAISSANCE BOULEVARD, SUITE 100KING OF PRUSSIA, PA 19406-2713

IF YOU ARE LOCATED IN:

ILLINOIS, INDIANA, IOWA, MICHIGAN, MINNESOTA, MISSOURI, OHIO, OR WISCONSIN,SEND APPLICATIONS TO:

MATERIALS LICENSING BRANCHU.S. NUCLEAR REGULATORY COMMISSION, REGION III2443 WARRENVILLE ROAD, SUITE 210LISLE, IL 60532-4352

ALASKA, ARIZONA, ARKANSAS, CALIFORNIA, COLORADO, HAWAII, IDAHO, KANSAS,LOUISIANA, MISSISSIPPI, MONTANA, NEBRASKA, NEVADA, NEW MEXICO, NORTHIDAKOTA, OKLAHOMA, OREGON, PACIFIC TRUST TERRITORIES, SOUTh DAKOTA, TEXAS,iUTAH, WASHINGTON, OR WYOMING,

SEND APPLICATIONS TO:

NUCLEAR MATERIALS LICENSING BRANCHU.S. NUCLEAR REGULATORY COMMISSION, REGION IV1600 E. LAMAR BOULEVARDARUINGTON, TX 76011-4511

PERSONS LOCATED IN AGREEMENT STATES SEND APPLICATIONS TO THE U.S. NUCLEAR REGULATORY COMMISSION ONLY IF THEYWISH TO POSSESS AND USE LICENSED MATERIAL IN STATES SUBJECT TO U.S.NUCLEAR REGULATORY COMMISSION JURISDICTIONS.

1. THIS IS AN APPLICATION FOR (Check appropriate 11am) 2. NAME AND MAILING ADDRESS OF APPLICANT (Include ZIP coda)

F] A. NEW LICNS

Hydro Resources, Inc.[-]B. AMNMN OUES UBRSUA-1580 62329 North Star Drive

Montrose, CO 81403H C. RENEWAL OF LICENSE NUMBER

3. ADDRESS WHERE LICENSED MATERIAL WILL BE USED OR POSSESSED 4. NAME OF PERSON TO BE CONTACTED ABOUT THIS APPLICATION

BUSINESS TELEPHONE NUMBER BUSINESS CELLULAR TELEPHONE NUMBER

BUSINESS EMAIL ADDRESS

SUBMIT ITEMS S THROUGH 11 ON 8-1/2 Xl11" PAPER. THE TYPE AND SCOPE OF INFORMATION TO BE PROVIDED IS DESCRIBED IN THE LICENSE APPLICATION GUIDE.

5. RADIOACTIVE MATERIAL 5. PURPOSE(S) FOR WHICH LICENSED MATERIAL WILL BE USED.

a. Element and mass number; b. chsmical and/or physical tormn; and c. maiximum amount 7 NIIULS EPNIL O RDAINSFT RGA N HI

whic wil heposssse at ny ne tme.TRAINING EXPERIENCE.

8. TRAINING FOR INDIVIDUALS WORKING IN OR FREGUENTING RESTRICTED AREAS. 9. FACILITIES AND EOUIPMEN1.

10. RADIATION SAFETY PROGRAM. 11. WASTE MANAGEMENT.

12. LICENSE FEES (Fees required only for" new applications, with few exceptions*)FE CAEGR F u T AMOUNT [(See 10 CFR 170 and Section 170.31) [FEE,,,CATEGORY,,,,,,,,,,,,j ENCLOSED $ 0.00 1

13. CERTIFICATION. (Must be completedi by applicant) VIE APPLICANT UNOERSTANDS THA TALL STA TEMENTS AND REPRESENTATIONS MACE IN THIS APPLICA TION ARE SINDINGUPON THE APPLICANT

THE APPLICANT AND ANY OFFICIAL EXECUTING THIS CERTIFICATION ON BEHALF OF THE APPUICANT, NAMED IN ITEM 2. CERTIFY THAT THIS APPLICATION IS PREPARED INCONFORMITY WITH TITLE 10, CODE OF FEDERAL REGULATIONS, PARTS 30, 32, 33, 34, 35 ,36, 37, 39, AND 40, AND THAT ALL INFORMATION CONTANED HEREIN IS TRUE AND CORRECTTO THE BEST OF THEIR KNOWLEDGE AND BELIEF.WARNING: 18 U.S.C. SECTION 1001 ACT OF JUNE 25, 1948 62 STAT. 749 MAKES IT A C RIMINAL OFFENSE TO MAKE A WILLFULLY FALSE STATEMENT DR REPRESENTATION TOANY DEPARTMENT OR AGENCY OF THE UNITED STATES AS TO ANY MATrER WITHIN ITS JURISDICTION.

CERTIFYING OFFICER -TYPED/PRINTED NAME AND TITLE SIGNATURE IDATE

~~FORNRCUSONLYI

COMMENTSili; ll~i • ~i!;E:!II1;:,.•:I• !* i, i ! •; ; ,!=i:1: '>•5••i=:!i

ItNRC FORM 313 (10-2015)