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4.5.2 Permits and Approvals
RER will be required to obtain permits and approvals to operate the Bull Hill Mine from the
Forest Service and from the Wyoming Department of Environmental Quality – Land Quality
Division (WDEQ-LQD). In accordance with the company Environmental, Health, and Safety
Policy, RER will comply with applicable federal and state environmental statutes, standards,
regulations, and guidelines in the permitting and operations of the Bull Hill Mine. Environmental
baseline studies have been initiated to meet the federal and state permit requirements.
This Plan of Operations provides the preliminary information that the Forest Service will use to
initiate the National Environmental Policy Act (NEPA) process. It is anticipated that because the
Bull Hill Mine will be located on federal lands, it will be considered a major federal action that
requires the preparation of an Environmental Impact Statement (EIS) under NEPA, the Council
of Environmental Quality (CEQ) guidelines, and Forest Service NEPA procedures. Operation of
the Hydromet Plant and TSF are part of the Bear Lodge Project. The Forest Service is currently
determining the level of analysis required in the NEPA document for these facilities on private
lands. Other associated facilities for impact assessment include the Miller Creek Access Road,
power transmission line, and other project components (the Waste Rock Facility including the
Low Grade Ore Stockpile, and water supply wells) located on private lands.
The NEPA review will begin once the Plan of Operations is approved for technical completeness
by the Forest Service. RER will enter into a Memorandum of Understanding (MOU) with the
Forest Service to prepare an EIS using a third party contractor. The MOU will define the roles of
the Forest Service and RER in the preparation of the EIS, require a professional services
agreement between RER and the third party EIS contractor, a disclosure statement of no
conflicts of interest from the EIS contractor, and a schedule for the completion of the EIS. The
culmination of the EIS process, following other federal agency and public review and comment,
will result in a Record of Decision and subsequent approval of the Plan of Operations by the
Forest Service.
The WDEQ-LQD in Sheridan, Wyoming is the responsible agency for the issuance of the
Permit-to-Mine. The permit application will include both the Bull Hill Mine and the Upton Plant.
The application will consist of detailed information describing the mineable resource,
adjudication of the lands in the Project Area, mine overburden (waste rock), topsoil, subsoil,
surface waters, groundwater, hydrology, water rights, cultural resources, mining plan, and a
detailed reclamation plan, including costs for bonding based on post-mining topography and
final land use.
RER has initiated the pre-operational baseline environmental studies required under WDEQ-
LQD mine permitting rules and regulations. The baseline studies are discussed in Section 5.0.
It is anticipated that additional permits, licenses, and approvals will be required from the U.S.
Army Corps of Engineers (USACE), Nuclear Regulatory Commission (NRC), WDEQ-Water
Quality Division (WQD), WDEQ Air Quality Division (AQD), the Wyoming State Engineers
Office, Wyoming State Lands, Wyoming Industrial Siting Division, and WDOT, as well as local
permits and approvals.
4.5.3 Project Schedule
Construction of the mine facilities and infrastructure is estimated to begin in the first quarter of
2016 once all permit and approvals are obtained, and will take up to 12 months to complete.
Production start-up is scheduled to begin in the fourth quarter of 2016. Ramp-up to full
