Worksheet Determination of NEPA Adequacy (DNA) U.S Department ofthe Interior, Bureau of Land Management A. Background BLM Office: Prineville NEPA Log#: DOI-BLM-OR-P060-2014-0040-DNA Project/Lease/Serial/Case File#: N/A Applicant: AltaRock Location: Newberry Crater in the Deschutes National Forest 10 miles NE of La Pine, OR Proposed Action Title: Revised Induced Seismic Mitigation Plan at Newberry Crater Background: AltaRock through its continuing development of Enhanced Geothermal Resources at Newberry Crater has requested that the BLM accept the Department of Energy's (DOE's) revised Induced Seismic Mitigation Plan (ISMP). The plan reduces the required flow back storage capacity onsite from 10 percent, as discussed in the existing Environmental Assessment (EA), to a capacity sufficient to accept the calculated flow back. The ISMP was incorporated by reference in the existing EA and Decision Record. Flow back storage (in sump ponds) is designed to accommodate water that could flash and come to the surface after injection into the hot rock at the bottom of the well. Since AltaRock proposes to inject 20 million gallons, it originally needed 2 million gallons of storage. The EA analyzed and the Decision Record allowed AltaRock to provide 1.4 million gallons of storage near the well and another 1.4 million gallons of storage 2.7 miles away, accessed via a temporary above ground pipeline. The reduced need for storage capacity would enable the company to meet its flow back storage capacity near the well and forgo the need for the pipeline and additional sump ponds. Description of the Proposed Action: Allow AltaRock to reduce onsite flow back storage capacity from 10 percent to 5 percent, or a capacity sufficient to accept the calculated flow back using the most current ISMP if different. B. Land Use Plan Conformance The proposed Project is located on federal lands managed by the Forest Service. Land Management Plans (Deschutes National Forest LRMP (1990) and Newberry National Volcanic Monument Plan (1994)) have been completed for all lands upon which activities are proposed, both lands leased for geothermal exploration and unleased lands. In accordance with the National Forest Management Act (NFMA) and the Newberry National Volcanic Monument Act, all activities on National Forest lands must be consistent with the applicable management plans. The proposed action is in conformance with the applicable plan because it is specifically provided for in the following land use plan decisions: Forest management goals reflect a vision for all Forest resources including a goal to "provide for exploration, development, and production of energy resources on the Forest while maintaining compatibility with other resource Page 1 values." (LRMP p. 4-2). Drill pads, pipelines, power plants, and electrical transmission lines, to the extent possible, are designed and located to minimize impacts on other resources, particularly visual quality." (LRMP p. 4-6). C. Identify applicable National Environmental Policy Act (NEPA) documents and related documents that cover the proposed action The following NEP A documents (EA, DEIS, FEIS) cover the proposed action: Newberry Volcano Enhanced Geothermal System (EGS) Demonstration Project Environmental Assessment (EA) DOI-BLM-OR-P000-2011 & DOE/EA-1897 (Decision Record signed April 15, 2012) D. NEPA Adequacy Criteria 1. Is the new proposed action a feature of, or essentially similar to, an alternative analyzed in the existing NEPA document(s)? Is the project within the same analysis area, or if the project location is different, are the geographic and resource conditions sufficiently similar to those analyzed in the existing NEPA document(s)? If there are differences, can you explain why they are not substantial? Yes, the new proposed action is similar to Alternative A in the EGS EA which analyzed storage capacity sufficient to accept flow back from water injection into the geothermal exploration well. 2. Is the range of alternatives analyzed in the existing NEPA document(s) appropriate with respect to the new proposed action, given current environmental concerns, interests, and resource values? Yes, the range of alternatives originally analyzed is appropriate with current environmental concerns, interests, and resource values. Nothing changes other than the calculated flow back storage capacity, which would mean there would be no need for a temporary 2lh mile above ground water pipeline to additional storage (as analyzed in the EA and approved in the Decision Record). 3. Is the existing analysis valid in light of any new information or circumstances (such as rangeland health standard assessment, recent endangered species listings, updated lists of BLM sensitive species)? Can you reasonably conclude that all new information and new circumstances would not substantially change the analysis of the new proposed action? Yes the existing analysis is valid. While there is new information from the DOE about adequate flow back water storage capacity, this new information does not result in effects outside those already considered in the EGS EA. The EGS already included analysis of providing adequate flow back water storage capacity. 4. Are the direct, indirect, and cumulative effects that would result from implementation of the new proposed action similar (both quantitatively and qualitatively) to those analyzed Page 2 in the existing NEPA document(s)? The direct, indirect and cumulative effects of the proposed action would be similar to those of Alternative A and described on pages 92-143 of the EGS EA. The effects would be less than those described because there would be no need for a 2 Yz mile temporary above ground water pipeline. 5. Are the public involvement and interagency review associated with existing NEPA document(s) adequate for the current proposed action? Yes, the extensive public involvement and interagency review conducted for the EGS EA is adequate for the current proposed action. The proposed change in required flow back water capacity does not trigger additional outreach because the action and its potential effects were adequately covered in the EGS EA, which was available for public review in 2012. A final copy of this DNA will be posted on the Prineville District's internet page for public review. A printed copy will be available on request. E. Preparers (BLM) Title Geologist Planning & Environmental Coordinator Note: Refer to the EGS EA for a complete list of the team members participating in the preparation ofthe original environmental analysis. Conclusion Based on the review documented above, I conclude that this proposal conforms to the applicable land use plan and that the existing environmental analysis fully covers the proposed action and constitutes BLM's compliance with the requirements ofthe NEPA. 8/o/('f Signature Responsible official: f; Date Note: The signed Conclusion on this worksheet is part of an interim step in the BLM's internal decision process and does not constitute an appealable decision. However, the lease, permit, or other authorization based on this DNA is subject to protest or appeal under 43 CFR Part 4 and the program specific regulations. Contact Person(s) For additional information concerning this review, contact: Steve Storo, Prineville Field Office, 3050 NE 3rd Street, Prineville, OR 97754, telephone (541) 416-6700. Page 3
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