4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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4.10 Wild Horses 

4.10.1 Agency-Required Measures 

The management practices for wildlife (Section 4.9) would be beneficial to wild 

horses as well as wildlife and are established in conjunction with the BLM, 

WGFD, and USFWS guidelines and regional recommendations (BLM, 2008b; 

WGFD 2008c; and WGFD, 2009). In addition to the measures discussed in 

Section 4.9, the installation of pitless cattle guards under the gates to the mine 

units would be used as an additional protection measure. The purpose of these 

cattle guards is to deter wild horses from entering a mine unit should the gate to 

that mine unit be left open inadvertently. Alternately, an automatic closure would 

be put on the gate. 

The management practices would also help minimize impacts to plant 

communities and associated forage and habitat. Standard construction, erosion 

control, and other agency-required measures described in other sections would 

also help to minimize impacts to wild horses. 

4.10.2 Monitoring of Wild Horse Impacts 

An annual record of all wild horse mortality due to fence entanglements, vehicle 

collisions, and other factors would be completed to help minimize adverse 

impacts to wild horses. 

4.10.3 Impact Significance Criteria 

Habitat loss or alteration, incremental habitat fragmentation, displacement of, and 

stresses on, wild horses, and direct or indirect mortalities were considered in order 

to assess the significance of impacts on wild horses. The availability of adjacent 

habitat and the size of the horse population were also considered. 

These criteria are in accordance with the Rawlins RMP Management Goals, 

which aim to protect the health and viability of herds while retaining the freeroaming nature of wild horses. 

4.10.4 Impacts from the Proposed Action 

Wild horses rely on the same available habitats for survival as wildlife big game; 

as a result, direct habitat impacts would generally be similar to Project impacts to 

big game in the region (Section 4.9). 

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4.10.4.1 Construction 

The Construction phase includes the Initial Construction and progressive Mine 

Unit Development. Initial Construction would require about one year. Most of 

the disturbance during Initial Construction would be long-term, i.e., lasting for the 

duration of the Project, because it would include vegetation removal from the 

areas on which Project facilities would be built. During Mine Unit Development, 

the impacts would be similar to those during Initial Construction, but the facilities 

being constructed would be smaller, e.g., header houses, and the facilities would 

be in place for the life of the mine unit, but not the life of the Project. Section 

4.8.4.1 includes a more detailed discussion. 

During the Construction phase, potential impacts to wild horses include loss 

and/or modification of habitat, increased disturbances due to human presence, and 

direct mortality (from vehicle collisions, entanglement in new fences or cattle 

guards, or getting stuck in trenches). 

During Initial Construction, approximately 95 acres (rounded to closest 5 acres) 

would be disturbed (two percent of the total Permit Area). Approximately 80 

percent of this disturbance is in the Upland Big Sagebrush Shrubland, with the 

rest, about 20 percent, in the Lowland Big Sagebrush Shrubland (Table 4.5-1). 

These 95 acres of disturbed land represent a long-term direct impact of a small 

percentage of available habitat within any of the HMAs (Figure 3.9-1). Since 

only a small percent of the total Permit Area would be disturbed, wild horses are 

expected to disperse from the Permit Area as Construction activities approach. 

During Initial Construction, approximately ten acres within the Permit Area 

would be restricted from wild horses due to fencing around the Plant (Section 

2.1.2.6). 

During Mine Unit Development, the habitat disturbance would be similar to that 

during Initial Construction, but the facilities being constructed would be smaller, 

e.g., header houses, and the facilities would be in place for the life of the mine 

unit, but not the life of the Project. The total area of vegetation disturbance 

(primarily vegetation crushing in the pattern areas) during Mine Unit 

Development of all mine units is on the order of 240 acres. All but about 85 

percent of this disturbance is in the Upland Big Sagebrush Shrubland, with the 

rest, about 15 percent, in the Lowland Big Sagebrush Shrubland. Approximately 

50 acres of disturbance would occur for the first mine unit, and 95 acres for the 

next two mine units (Section 4.8). The pattern areas within these mine units 

would be fenced to restrict wild horses from entering (Figure 2.1-5 and Section 

2.1.2.6). The ISR process is iterative; new mine units are brought into production 

as older mine units are reclaimed. Therefore, not all of the disturbance would 

occur at once, and the disturbance is clustered, which would help minimize 

disruptions to wild horses. 

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Increased noise from Construction equipment could cause wild horses on-site to 

relocate; however, the equipment noise is expected to be indistinguishable from 

the wind noise at the Permit Area boundary nearest to the Construction activity 

(Section 3.11). Therefore, noise from Construction activities would not affect 

wild horses outside of the Permit Area and is not expected to impact horses in 

many parts of the Permit Area that are further from the Construction activities. 

Increased traffic in the Permit Area could impact wild horses due to an increase in 

noise and an increased chance of direct casualties due to vehicle collisions. 

During Construction, increased heavy equipment would be transported to the 

Permit Area. The volume of traffic associated with the Project is expected to be 

relatively small; and, due to the concentrated nature of the resource, the 

comparatively small workforce associated with the Project; and the restricted time 

of work hours, impacts to wild horses from increased traffic would be negligible. 

The increased traffic would create dust that may settle on vegetation, making it 

temporarily less palatable and creating a short-term reduction in forage available 

to the wild horses. 

Increased human presence due to Construction may affect wild horse use of areas 

adjacent to the Permit Area (e.g., the stock pond south of the East Access Road). 

Although these indirect impacts are possible, wild horses are transitory and would 

likely find nearby suitable habitat free from areas of human activity and 

disturbance. More detrimental impacts could occur if the disturbed area included 

a source of water for the wild horses, but, as discussed in Section 3.5, the Permit 

Area has no standing water for nearly the entire growing season, and no wetlands 

were identified. Forage losses due to Construction would be mitigated via staged 

reclamation of disturbed areas, providing grass and forb forage within a few years 

of habitat disturbance. Impacts to wild horses would be minimal because these 

species are highly mobile, the area of disturbance is relatively small compared to 

adjacent similar habitats, and on-site water sources are not present. Therefore, 

impacts are not expected to threaten the continued existence of the wild horse 

population in the Permit Area and surrounding habitat. 

Section 4.6 of the NRC SEIS summarizes the potential impacts to wildlife in the 

Permit Area and includes an analysis of wild horses. Since wild horses are 

mobile and only a small percentage of the land would be influenced by the 

Construction, Operation, and Reclamation associated with this Project, no 

significant impacts to the population are expected (NRC, 2011a). 

4.10.4.2 Operation 

The Operation phase of the Project includes the production from the mine units. 

During the Operation phase, there would be little, if any, new habitat disturbance. 

The primary impacts of Operation on wild horses are habitat alteration and 

incremental habitat fragmentation, displacement/stress from human activity, and 

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direct and/or indirect mortalities. There is also a potential for exposure to spills 

containing trace quantities of toxic chemicals and compounds during the 

Operation phase. 

Approximately 300 acres within the Permit Area would be fenced to keep out 

cattle and wild horses. While this fencing may affect the movement of horses, 

requiring them to travel around the fenced areas, the fencing is not expected to 

increase fragmentation of herds, due to the relatively small fenced area. 

Temporary mud pits would be fenced if they are located outside of the fenced 

portion of the mine units. Inside the fenced portion of the mine units, mud pits 

would not be fenced, in part due to the limited time the pits are open and the level 

of activity around the pits while they are open. Temporary mud pits (within the 

fenced pattern area or individually fenced if not within the pattern area) have not 

been the cause of significant mortality to big game at other ISR operations. (Most 

other ISR operations are in areas with more domestic than wild horses.) 

Therefore, the mud pits are not anticipated to impact wild horses. 

During Operation, spills around wellheads and leaks from pipelines could expose 

wild horses to trace quantities of toxic chemicals. LCI's leak detection systems 

and SPCC plan to remove affected soils and capture release fluids would 

eliminate or reduce such impacts. 

Similarly to the Construction phase, increased traffic creates dust that could land 

on the adjacent vegetation, reducing the quality of available forage in the shortterm, and creating a higher competition for the remaining plant resources. 

Wild horse use of areas adjacent to ISR operations is anticipated to increase as 

animals become habituated to mining activity. Because wild horses may be in 

proximity to Project buildings, roads, and mine units, some impacts to the horses, 

such as collisions with fences, would be expected to occur. 

Traffic volume during the Operation phase would likely be on the same order as 

for Construction; however, there would be less transport of heavy equipment and 

more transport of wastes and yellowcake slurry off-site (Section 4.3). These 

activities could reduce wild horse use within the Permit Area, resulting in a higher 

concentration of animals in the surrounding habitat. Noise from Operation 

activities is expected to be lower than that generated during Construction 

activities (Section 4.12). Also, considering the size of the comparable 

surrounding habitat, impacts would are expected to be minimal because only a 

few bands of wild horses would be affected in each HMA. Operational impacts 

are not expected to threaten the continued existence of the wild horse population 

in the Permit Area and surrounding habitats. 

Section 4.6 of the NRC SEIS summarizes the potential impacts to wildlife in the 

Permit area and includes an analysis of wild horses. Since wild horses are mobile 

and only a small percentage of the land would be influenced by the Construction, 

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Operation, and Reclamation associated with this Project, no significant impacts to 

the population are expected (NRC, 2011a). 

4.10.4.3 Reclamation 

There should be no additional habitat disturbance during Mine Unit or Final 

Reclamation. Short-term land disturbance would occur during decommissioning 

of supporting facilities and roads, as soils are excavated, buried piping is 

recovered and removed, and structures are demolished and removed. 

Revegetation and recontouring would restore habitat previously altered during 

Construction and Operation. Once the structures were removed, the area of the 

Plant and Storage Ponds would be regraded to pre-construction contours, and then 

topsoil would be reapplied and seeded with native vegetation. 

No loss of additional vegetative communities is expected beyond those previously 

disturbed during Construction and Operation. The removal of piping would 

impact vegetation that has reestablished itself, although this, too, would be 

temporary once the disturbed soil is reseeded. Wild horses would be temporarily 

displaced, but are expected to return after Reclamation is completed and 

vegetation and habitat are reestablished. As the areas are reseeded with the 

permanent seed mix, there could be changes in the proportion of various species, 

including an increase in weeds. The presence of weeds could potentially affect 

habitat desirability and forage availability. However, actions would be taken to 

mitigate weed invasion. Wild horses are mainly grazers, increased grazing 

intensity could occur on newly seeded areas. Fences would be removed after ISR 

operation is complete and vegetation has become reestablished in accordance with 

permit requirements (Section RP 4.5.4 of the WDEQ-LQD Permit to Mine [LCI, 

2011b]) unless otherwise approved and agreed upon with the landowners (BLM 

and the State of Wyoming). Overall, impacts from Reclamation would be 

considerably less than those associated with Construction and Operation. 

Soil contamination could result from leaks and spills during Reclamation, and 

wild horses could then be exposed to the contaminated soils. However, detection 

and response techniques, and survey and treatment (if necessary) of all impacted 

soils, would limit the magnitude of overall impacts to wild horses. 

The Reclamation activities are expected to create temporary increases in noise 

and traffic (in comparison with the Operation phase) as buildings are taken down 

and hauled away. During this time, wild horses could come in conflict with heavy 

equipment, or may move elsewhere on the property due to higher-than-normal 

noise. However, these impacts would be short-term in nature. 

Section 4.6 of the NRC SEIS summarizes the potential impacts to wildlife in the 

Permit area and includes an analysis of wild horses. Since wild horses are mobile 

and only a small percentage of the land would be influenced by the Construction, 

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Operation, and Reclamation associated with this Project, no significant impacts to 

the wild horse population are expected (NRC, 2011a). 

4.10.5 Wild Horse Impacts from Other Alternatives 

4.10.5.1 No Action Alternative 

Under the No Action Alternative, there would be no ISR facility construction 

associated with the Project, and therefore no habitat disturbance associated with 

Construction, Operation, and Reclamation would occur. The area would continue 

to provide vegetation communities and habitat typical of the region. Land would 

continue to be used for rangeland available to wild horses within the HMAs. 

Impacts from other existing activities, such as cattle grazing, mineral exploration, 

recreation, and hunting would continue. 

4.10.5.2 Not Fencing the Pattern Areas 

There would be a slight reduction in the acres of vegetation and habitat 

disturbance if the fences around the patterns areas are not constructed. However, 

the protection measures in the pattern areas, specifically reseeding, would be 

adversely impacted as the new vegetation growth in the reseeded areas would be 

preferred by livestock and wild horses. Also, without the fencing in place, 

collisions or entanglement of wild horses with fences would not occur. Without 

fencing there would be a higher likelihood of wild horse exposure to spills 

containing trace quantities of toxic substances and other operational hazards, such 

as collision with well heads. 

4.10.5.3 Drying Yellowcake On-Site 

This alternative would have minimal additional impacts on habitat resources at 

the Permit Area, as the dryer would be within the Plant. There would be an added 

potential for harmful leaks to occur; however, this potential would be mitigated 

through proper operational precautions and risk management. 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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4.11 Air Quality 

4.11.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Sections OP 2.10 and OP 5.1.1 of the WDEQ-LQD Permit to Mine (LCI, 2011b), 

the WDEQ-AQD Permit, Section 7.5 of the NRC Technical Report (LCI, 2010), 

Sections 2.1.1.1.6.1 and 6.4 of the NRC SEIS (NRC, 2011a), and Condition 12.8 

of the NRC License (NRC, 2011b). Emissions and potential impacts from radon 

gas are discussed in Section 4.17. 

LCI would use BMPs to reduce fugitive dust and emissions. These BMPs 

include: 

•	 Per the Air Quality Permit issued by WDEQ-AQD (Permit CT-7896), LCI 

would necessarily reduce fugitive dust emissions using standard dust 

control measures (e.g., water or chemical dust suppressant application on 

roads controlled by LCI on a schedule “sufficient to control fugitive dust 

from vehicular traffic”, reduced speed limits, encourage employee 

carpooling, etc.); 

•	 Reduce maximum fugitive dust by coordinating dust-producing activities; 

•	 Use fossil-fuel vehicles that meet applicable emission standards; 

•	 Reclaim or revegetate disturbed areas; 

•	 Reduce diesel particulate matter emissions using measures such as particle 

traps and other technological or operational methods; 

•	 Ensure that diesel-powered construction equipment is properly tuned and 

maintained; 

•	 Use ultra-low sulfur diesel fuel; 

•	 Use newer, cleaner equipment; 

•	 Avoid leaving equipment unnecessarily idling or operating; 

•	 Standardize delivery procedures to minimize material loss (as well as 

address health and safety concerns); 

•	 Use efficient construction and demolition practices; 

•	 Ensure vapor control equipment (e.g., laboratory hoods) is operating 

correctly to both reduce emissions and protect personnel; and 

•	 Per the Air Quality Permit issued by WDEQ-AQD (Permit # CT-7896), a 

scrubber would install and maintain a scrubber for used during loading of 

the HCl storage tank. 

Many of the above BMPs address minimizing use of or burning fossil fuels more 

efficiently. These practices would effectively reduce GHG emissions as well. 

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4.11.2 Monitoring of Air Quality Impacts 

Specific monitoring is not required per the provisions of the WDEQ-AQD Air 

Quality Permit. Dust would be the most visible component of the emissions from 

the Project; therefore, attention to visibility conditions would be necessary to 

ensure the environmental protection measures required by the permit are applied 

timely for best effect. Several air monitoring networks exist in the region of the 

Permit Area, as outlined below. 

There are three State and Local Air Monitoring Sites (SLAMs) in Sweetwater 

County; the sites are located in Rock Springs, Moxa, and Wamsutter. The closest 

SLAM to the Permit Area is in Wamsutter (approximately 25 miles southsouthwest of the Permit Area), which records NOx, ozone, and continuous 

particulate concentrations (PM10 tapered element oscillating microbalance 

(TEOM)) and houses a camera system and meteorology monitors. The Wamsutter 

site is upwind, as is the Rock Springs site (approximately 80 miles southwest of 

the Permit Area), which records PM2.5 and PM10 concentrations. The site in 

Moxa (approximately 110 miles west-southwest of the Permit Area) has the same 

capabilities as the Wamsutter site and also monitors SO2. There are no SLAMS in 

Carbon County, the nearest downwind county. However, there are SLAMs in 

Natrona County and Albany County (approximately 100 miles northeast and 

approximately 150 miles southeast of the Permit Area, respectively). Both of 

these downwind sites collect only PM2.5 and PM10 concentrations. The nearest 

downwind site measuring gaseous emissions is in Campbell County 

(approximately 200 miles northeast (WDEQ, 2010b). 

The purpose of the Interagency Monitoring of Protected Visual Environments 

(IMPROVE) network is to establish current visibility and aerosol conditions along 

with characterization of broad regional trends and visibility conditions using 

monitoring data collected in or near Class I Areas across the United States. 

Wyoming has five IMPROVE locations which include: Yellowstone National 

Park (approximately 200 miles northwest of the Permit Area), Bridger Wilderness 

Area (approximately 100 miles northwest of the Permit Area), North Absaroka 

Wilderness Area (approximately 180 miles northwest of the Permit Area), 

Thunder Basin National Grasslands (approximately 200 miles northeast of the 

Permit Area), and Cloud Peak Wilderness Area (approximately 180 miles north of 

the Permit Area) (WDEQ, 2010b). There are no IMPROVE sites downwind of the 

Permit Area in Wyoming. 

The purpose of the National Atmospheric Deposition Program (NADP) is to 

measure atmospheric deposition and study its effects on the environment. 

Deposition is measured at various sites, nationwide, through the National Trends 

Network (NTN). There are currently eight active NTN sites in Wyoming. The 

nearest NTN site to the Permit Area is in South Pass City (approximately 60 miles 

west-northwest of the Permit Area. The nearest upwind site is in Murphy Ridge, 

Utah (approximately 180 miles southwest of the Permit Area). The nearest 

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downwind site is in Newcastle (approximately 200 miles northeast of the Permit 

Area) (NADP, 2011). 

Finally, there are three active Clean Air Status and Trends Network (CASTNET) 

sites in Wyoming: Centennial, Pinedale, and Yellowstone National Park. These 

sites have been designed to provide data to assess trends in air quality, 

atmospheric deposition, and ecological effects due to changes in air pollutant 

emissions. The closest site to the Permit Area is in Centennial (approximately 100 

miles southeast of the Permit Area. There are no nearby upwind CASTNET sites 

and the closest downwind site is in Wind Cave National Park in South Dakota 

(approximately 200 miles northeast of the Permit Area) (EPA, 2011a). 

4.11.3 Impact Significance Criteria 

The airborne emissions of the Project are identifiable, and emission levels are 

estimated to evaluate the potential impacts on ambient air quality from the 

different phases of the Project, i.e., Construction, Operation, and Reclamation. 

Potential impacts on air quality from the Project are evaluated in consideration of 

the WAAQS, NAAQS, PSD, and Regional Haze Regulations. The WAAQS and 

NAAQS set legally enforceable upper limits for specific air pollutant 

concentrations. If an area meets the standards, it is considered to be in 

“attainment”. PSD requirements provide maximum allowable increases in 

concentrations of pollutants for areas already in compliance with the NAAQS. 

PSD standards are, therefore, expressed as allowable increments in the 

atmospheric concentrations of specific pollutants. Allowable PSD increments 

currently exist for three pollutants: NO2, SO2, and PM10. One set of allowable 

increments exists for Class II areas, which cover most of the US. A much more 

stringent set of allowable increments exists for Class I areas, which are 

specifically designated areas where the degradation of ambient air quality is 

severely restricted. Regional Haze Regulations were developed to maintain and 

improve visibility in PSD Class I areas. 

The Project was also evaluated in consideration of whether it would be a major 

source in accordance with WDEQ regulations and whether any Hazardous Air 

Pollutants (HAPs) would be present. The potential impacts of those portions of 

the emissions that are greenhouse gases and contribute to climate change are more 

difficult to quantify and depend on relative comparisons to other sources. 

Therefore, the potential impacts of greenhouse gases and climate change from the 

Project as a whole are evaluated by comparing Project greenhouse gases (GHGs) 

emissions to statewide emissions. 

4.11.4 Air Quality Impacts from the Proposed Action 

The Project is expected to be a source of airborne emissions throughout its life. 

Emissions would include: 

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 fugitive dust; 

 combustion engine exhausts; 

 particulates and gaseous emissions from materials used in Project 

activities, such as drilling (e.g., drilling mud) and ore processing (e.g., 

salt); and 

 radon gas. 

The significance of the impacts of fugitive dust, engine exhausts, particulates, and 

other gaseous emissions on the ambient air quality from the Project depends on 

the emission levels of the Proposed Action, the existing air quality in the region of 

influence, and the threshold to separate significant from non-significant effects. 

This section discusses predicted emissions from each phase of the Project in 

relation to relevant air quality regulations and potential impacts with 

consideration of site-specific conditions. Emissions and potential impacts from 

radon gas are discussed in Section 4.17. The only potential non-radiological HAP 

emission is hydrogen chloride, which is used for ore processing in the Plant and is 

discussed in Section 4.11.4.2. 

PSD applies to new major sources or major modifications at existing sources for 

pollutants when the area the source is located is in attainment or unclassifiable 

with the NAAQS. The Permit Area and surrounding land is classified as in 

attainment for NAAQS and WAAQS, and does not include any PSD Class I or 

Sensitive Class II areas. The nearest PSD Class I areas, Bridger Wilderness, 

Fitzpatrick Wilderness, and Mt Zirkel (WDEQ, 2011b), are located about 60, 100, 

and 90 miles, respectively, to the northwest and south (Mt. Zirkel) of the Lost 

Creek site. The Popo Agie Wilderness area is the closest Sensitive Class II area 

and is located about 58 miles to the northwest of the Lost Creek site (NRC, 

2011a). 

WDEQ-AQD issued an air quality permit for the Project on January 4, 2010. The 

Project is not considered a “major source” as defined in Chapter 6, Section 3 of 

the Wyoming Air Quality Standards and Regulations (WDEQ, 2010a). 

Therefore, air quality modeling is not necessary. Air emissions from the proposed 

Lost Creek ISR Project would comply with the conditions of the WDEQapproved construction air permit and the required WDEQ minor source operating 

permit. Due to the wind and relative instability of the air, emissions would 

generally be quickly dispersed (Section 3.10). As such, it is not expected that the 

predicted Project emissions would impact attainment for ambient air quality 

standards in the region surrounding the Permit Area. Furthermore, emissions are 

not expected to impact air quality in the Class I or Class II areas in the vicinity of 

the proposed Lost Creek ISR Project, as the areas are located at least 50 miles 

from the Permit Area and are upwind the majority of the time (Figure 3.10-4). 

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4.11.4.1 Construction 

Air quality impacts during Initial Construction would come primarily from 

ground-clearing activities and transportation of materials and personnel. The 

primary emissions would be dust and emissions from combustion engines, which 

would power equipment ranging from light trucks to heavy equipment. Emissions 

other than dust or engine exhausts would be minimal. 

Mine Unit Development is included under construction, although the development 

of the mine units is progressive (one mine unit may be under development while 

another mine unit is in operation). During Mine Unit Development, there would 

be some air quality impacts from emissions and dirt-moving activities during 

header house and pipeline installation. However, the quantity of dust from these 

activities would be a small fraction of that from road traffic. 

According to Section 4.7.1.1 of the NRC SEIS, potential impacts to air quality in 

the region during Construction result from fugitive dust and combustion 

emissions from the vehicles and equipment used. It is believed that all of these 

emissions would not result in concentrations above the air quality standards, and 

that the only potentially significant impact would be the visual impact the fugitive 

dust emissions could have (NRC, 2011a). 

Dust 

Localized, short-term and intermittent visible dust would be possible in the 

immediate vicinity of the Permit Area (i.e., when vehicles travel on unpaved 

roads). These impacts would be reduced, but not eliminated, by road treatments 

required per the WDEQ-AQD permit (WDEQ, 2010a). To estimate the 

maximum annual amount of dust generated from Project traffic, calculations 

using EPA Emission Factors for unpaved and paved roads were made. These 

calculations do not include any reduction for road treatment. The equations and 

assumptions for these calculations can be found in Appendix H. 

Most of the dust, generated from all vehicles, originates from travel on unpaved 

roads. The greatest amount of dust, assuming no road treatment, would be 

generated from employee and contractor vehicles during Initial Construction 

(approximately 170 tons per year of PM10). Mine Unit Development would also 

generate dust emissions, but less than during Initial Construction due to the 

reduced vehicular traffic (e.g., less than half the number of commuting vehicles 

with some vehicles remaining on-site). 

Combustion Engines 

Emissions would originate from a variety of engines on employee vehicles, 

tractor/trailers delivering equipment and supplies, scrapers and other earth moving 

equipment, welding machines, drilling rigs, and other equipment used for 

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Construction. Most of the combustion emissions from the employee vehicles are 

expected to be from gasoline engines and from the heavier equipment are 

expected to be from diesel engines. 

Table 4.11-1 includes the estimated engine emissions during Initial Construction. 

Estimating the number of vehicles and type of equipment is difficult because of 

overlapping uses of the equipment for different Project phases. In addition, to 

simplify the estimate, it is assumed that some activities all occur during the initial 

seven-month period. For example, it was assumed that all of the UIC Class I 

wells would be drilled during the initial seven-month Construction period. 

However, one of the wells was installed in 2008 to provide the necessary 

subsurface information to determine the feasibility of deep well disposal, and it is 

unlikely that the other four would be drilled in the same year, due in part to rig 

availability and expense. In addition, only those wells needed would be drilled. 

Table 4.11-1 Estimated Engine Emissions during Initial Construction 

(tons/year) 

Drilling Activity NOx CO SO2 PM10 CO2 Formaldehyde VOCs 

Commuting Traffic 1 0.66 8.6 -- 2 <0.01 279 -- --

Truck Deliveries 3 5.24 0.48 -- <0.1 251 -- <0.1 

Construction 

Equipment 4 2.5 0.55 0.17 0.18 94 0.00068 0.20 

Total Estimate 8.40 9.63 0.17 0.18 624 0.00068 0.20 1 Using emission factors from EPA (2005) for a single vehicle multiplied by the expected number of 

vehicles in Table 4.3-1, for initial construction this was estimated to be 33 trucks/SUVs. 2 Dashes (--) indicate information not provided in reference. 3 Using emission factors from Federal Highway Administration (2005) for combination 

(tractor/trailer) diesel trucks built in 2002 on rural freeways for all parameters except CO2; using 

emission factors from EPA (2004b) for CO2 from moderate, heavy duty diesel vehicles. Mileage 

for calculating emissions assumed two 500-mile round trips (1,000 miles total) per week for 

seven months. Emissions were then multiplied by the expected number of vehicles in Table 4.3-

1, for initial construction this was estimated to be five tractor/trailers. 4 Table D.3-2 of Appendix D of NRC SEIS (NRC, 2011a). 

It should also be noted that this estimate includes emissions from activities that do 

not occur exclusively on-site. In particular, the emissions attributable to off-site 

employee traffic and truck deliveries are included. Another important 

consideration is that the definition of Initial Construction for this estimate 

includes the installation of the Plant and associated facilities, but not Mine Unit 

Development, which is considered separately. This was done because the 

equipment needed for installation of the Plant and associated facilities, such as 

scrapers and dozers, is not the same as that needed for installation of the mine 

units, such as drill rigs and backhoes. Estimated engine emissions during Mine 

Unit Development are included in Table 4.11-2. The estimate is provided on an 

annual basis because the work would progress throughout each year mine units 

are being installed, which occurs over about five years. 

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Other Particulate or Gaseous Emissions 

Construction activities may also generate airborne particulates other than dust or 

those generated during combustion. Examples of such particulates during the 

Initial Construction might be welding fumes or dust from grinding on steel, and 

examples of such particulates during Mine Unit Development might be drilling 

mud or cement dust during the installation of wells. However, because of the 

relatively small size of the Project facilities, these emissions are estimated to be 

negligible and the primary concern would be potential health impacts to workers 

in the immediate vicinity of the emission-generating activity. 

Table 4.11-2 Estimated Annual Engine Emissions during Mine
 

Unit Development (tons/year)
 

Drilling Activity NOx CO SO2 PM10 CO2 Formaldehyde VOCs 

Commuting 

Traffic 1 0.3 3.9 -- 2 <0.01 126 -- --

Truck Deliveries 3 3.6 0.33 -- <0.1 186 -- <0.1 

Mine Unit Well 

Drilling & Support 

Equipment 4 

17 4.2 0.44 0.66 800 0.0013 0.66 

Total Annual 

Estimate 20.9 8.43 0.44 0.66 1112 0.0013 0.66 

1 Using emission factors from EPA (2005) for a single vehicle multiplied by the expected 

number of vehicles in Table 4.3-1; for mine unit development, this was estimated to be 15 

trucks/SUVs. 2 Dashes (--) indicate information not provided in reference. 3	 Using emission factors from Federal Highway Administration (2005) for combination 

(tractor/trailer) diesel trucks built in 2002 on rural freeways for all parameters except CO2; 

using emission factors from EPA (2004b) for CO2 from moderate, heavy duty diesel vehicles. 

Mileage for calculating emissions assumed two 500-mile round trips (1,000 miles total) per 

week. Emissions were then multiplied by the expected number of vehicles in Table 4.3-1, for 

mine unit development this was estimated to be two tractor/trailers. 4 Table D.3-1 of Appendix D of NRC SEIS (NRC, 2011a). 

4.11.4.2 Operation 

Air quality impacts during the Operation phase would come primarily from 

transportation of personnel and materials, and the primary emissions would be 

dust and emissions from combustion engines on lighter vehicles, such as SUVs, 

and heavier equipment, such as drill rigs. In addition to dust and to emissions 

from combustion engines, small amounts of particulates from materials used in 

Project activities, such as ore processing (e.g., salt) would be emitted. 

Section 4.7.1.2 of the NRC SEIS discusses the potential impacts to air quality 

during the Operation phase. Several concerns involve fugitive dust, combustion 

emissions from the vehicles and equipment used, and the release of radon during 

Operation. It is believed that all of these emissions would generate concentrations 

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below the air quality standards, and that the only potentially significant impact 

would be the visual impact the fugitive dust emissions could have (NRC, 2011a). 

Dust 

Significantly fewer personnel vehicles are needed during Operation than during 

Construction, so the quantity of dust generated would be less than that during 

Construction. Trucks used for resin shipments are estimated to generate 4.3 tons 

of dust per year; and delivery trucks are estimated to generate 2.7 tons per year. 

Combustion Engines 

Most of the emissions during Operation would originate from a variety of engines 

in employee vehicles, and tractor/trailers delivering equipment and supplies. 

Most of the combustion emissions from employee vehicles are expected to be 

from gasoline engines and those from heavier equipment are expected to be from 

diesel engines. The quantities would be significantly less than those generated by 

the Mine Unit Development activities. 

Other Particulate or Gaseous Emissions 

Airborne particulates may include minor amounts of salt and soda ash releases 

during deliveries to and use at the Plant. An analysis of soda ash emissions shows 

that approximately 13.5 pounds of particulate would be released per year. The 

analysis assumes that 5.2 pounds of particulate is created per ton used, and 521.1 

tons of soda ash would be used each year. Although 1.35 tons of particulate is 

created each year, a standard passive bag house filter would capture 99.5 percent 

of the material (using emission factors from EPA’s AP-42, Compilation of Air 

Pollutant Emission Factors, Volume 1 (EPA, 2006), resulting in a total emission 

of 13.5 pounds. A similar analysis of salt emissions, using a passive bag house 

filter, indicates that approximately 17.5 pounds of salt would be emitted per year, 

a minor contribution to the Project PM10 emissions, which are primarily dust. 

Liquid chemicals may be used in controlled amounts during groundwater 

restoration and for laboratory procedures. Venting of pressure at the mine units 

and supporting facilities would occasionally produce a low volume of nonradioactive gaseous emissions, such as CO2, oxygen, and water vapor. These can 

come out of solution from the lixiviant or from the underground environment. 

The only potential HAP emission is hydrogen chloride (HCl), which is used for 

ore precipitation at the Plant (Section 2.1.4). Permit # CT-7896, issued to LCI by 

WDEQ-AQD, includes specific conditions for use of a scrubber during loading of 

the HCl storage tank; therefore, no discernible impact is anticipated. 

Table 4.11-3 shows the estimated annual emissions during Operation, which is 

expected to be approximately seven years in duration. 

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Table 4.11-3 Estimated Annual Emissions during Operation 

(tons/year, unless otherwise noted) 

Drilling 

Activity NOx CO SO2 PM10 CO2 Formaldehyde VOCs Soda Ash (lbs/yr) 

Salt 

(lbs/yr) 

Commuting 

Traffic 1 0.06 0.78 -- 2 <0.01 25.4 -- -- -- --

Truck 

Deliveries 3 5.39 0.50 -- <0.1 258 -- <0.1 -- --

Plant 

Deliveries & 

Drilling4 

-- -- -- -- -- -- -- 13.5 17.5 

Total 

Annual 

Estimate 

5.45 1.28 -- 0.1 283 -- <0.1 13.5 lbs 17.5 lbs 

1 Using emission factors from EPA (2005) for a single vehicle multiplied by the expected number of 

vehicles in Table 4.3-1; for mine unit development, this was estimated to be three trucks/SUVs. 2 Dashes (--) indicate information not provided in reference. 3 Using emission factors from Federal Highway Administration (2005) for combination (tractor/trailer) 

diesel trucks built in 2002 on rural freeways for all parameters except CO2; using emission factors 

from EPA (2004b) for CO2 from moderate, heavy duty diesel vehicles. Mileage for calculating 

emissions assumed two 500-mile round trips (1,000 miles total) per week. Emissions were then 

multiplied by the expected number of vehicles in Table 4.3-1, for mine unit development this was 

estimated to be three tractor/trailers. 4 Using emission factors from EPA’s AP-42, Compilation of Air Pollutant Emission Factors, Volume 1 

(EPA, 2006) and usage information discussed above. 

4.11.4.3 Reclamation 

Reclamation would occur after completion of each mine unit (Mine Unit 

Restoration) as well as at the end of the project (Final Reclamation). Restoration 

of each mine unit is expected to take approximately one year, while Final 

Reclamation would take approximately three years. Potential air quality impacts 

during reclamation would include fugitive dust and emissions from combustion 

engines from many of the same sources identified for Construction. Impacts 

during Mine Unit Reclamation would be similar to those during Mine Unit 

Development, though of smaller quantities. During Final Reclamation, emission 

levels could increase in the short term, especially for particulate matter from 

activities such as dismantling buildings and equipment and grading the surface as 

part of Reclamation activities. Potential air quality impacts from Final 

Reclamation are initially expected to be similar to Initial Construction impacts 

and would decrease significantly as reclamation proceeds. Table 4.11-4 shows 

the upper limit of emissions during reclamation for the final year of the Project, 

where Mine Unit Restoration would overlap with Final Reclamation. Emissions 

would be far less during the remainder of reclamation. 

According to Section 4.7.1.1 of the NRC SEIS, potential impacts to air quality in 

the region from the Reclamation phase result from fugitive dust and combustion 

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emissions from the vehicles and equipment used. It is believed that all of these 

emissions would result in air concentrations below the air quality standards, and 

that the only potentially significant impact would be the visual impact the fugitive 

dust emissions could have (NRC, 2011a). 

Table 4.11-4 Estimated Annual Engine Emissions during 

Reclamation (tons/year)
 

Drilling Activity NOx CO SO2 PM10 CO2 Formaldehyde VOCs 

Commuting 

Traffic 1 0.24 3.1 -- 2 <0.01 101 -- --

Truck Deliveries 3 8.98 0.83 -- 0.11 430 -- 0.11 

Construction 

Equipment 

Needed for 

Reclamation of 

One Mine Unit & 

Plant Facilities3 

17 3.6 1.1 1.2 620 0.0045 1.3 

Total Annual 

Estimate 26.2 7.53 1.1 1.31 1151 0.0045 1.41 

1 Using emission factors from EPA (2005) for a single vehicle multiplied by the expected number 

of vehicles in Table 4.3-1; for reclamation, this was estimated to be 12 trucks/SUVs. 2 Dashes (--) indicate information not provided in reference. 3 Using emission factors from Federal Highway Administration (2005) for combination 

(tractor/trailer) diesel trucks built in 2002 on rural freeways for all parameters except CO2; 

using emission factors from EPA (2004b) for CO2 from moderate, heavy duty diesel vehicles. 

Mileage for calculating emissions assumed two 500-mile round trips (1,000 miles total) per 

week. Emissions were then multiplied by the expected number of vehicles in Table 4.3-1, for 

reclamation this was estimated to be five tractor/trailers. 3 Table D.3-6 of Appendix D of NRC SEIS (NRC, 2011a). 

4.11.4.4 Greenhouse Gases and Climate Change 

With respect to evaluation of the cumulative impacts on air quality of energyrelated projects with overlapping potentially affected areas, e.g., coal mining and 

oil and gas drilling, there are often concerns not only on the impacts of mining of 

the materials, but also on the impacts of the complete fuel cycle for those 

materials, especially as it relates to greenhouse gases and climate change. 

Conversely, there may also be concerns about the impacts of climate change on 

the Project. 

No practical methods exist to evaluate the contribution to climate change in a 

particular place from a single project. The Center for Climate Strategies 

generated a report for the WDEQ, showing the inventory and future greenhouse 

gas emissions for the State of Wyoming (CCS, 2007). Carbon dioxide is expected 

to be emitted at much higher levels than other GHGs during all phases of the 

Project. Comparing the annual emissions of CO2 from the Project to the statewide 

CO2 estimated annual emissions, the Project would produce less than 0.01 percent 

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of the net total greenhouse gases produced in Wyoming (NRC, 2011a). The 

percentages for other GHGs would be even less. The potential impacts of CO2 

and the other GHGs from the Project would thus be negligible. Evaluating the 

contribution to climate change from the complete nuclear fuel cycle indicates a 

low impact compared to other energy-related projects (IAEA, 1999). 

Due to the negligible CO2 contribution, and the natural decreases and increases in 

temperature in this part of Wyoming, attributing part of the climate change to the 

Project is speculative. In turn, the projected temperature change would have little, 

if any, impact on the Project (GCRP, 2009). With respect to an increase in 

precipitation, the natural variability is greater than 10 to 15 percent per year. 

Therefore, presuming the projected precipitation change was incremental over the 

next century, the impact on the Project would be negligible (GCRP, 2009). 

In Section 4.7 of the NRC SEIS, the amount of greenhouse gases emitted as a 

result of this Project is calculated to be a small fraction of the total projected 

emissions from the entire state of Wyoming and is considered insignificant (NRC, 

2011a). 

4.11.5 Air Quality Impacts from Other Alternatives 

4.11.5.1 No Action Alternative 

Under the No Action Alternative, there would be no change in the air quality at 

the Permit Area or at any surrounding receptor sites. The Permit Area currently 

meets the NAAQS for attainment status, and it is expected that this area would 

continue to meet the NAAQS. As noted in Section 3.10, current activities in the 

vicinity, including ranching, hunting, and grazing, do produce some emissions. 

4.11.5.2 Other Action Alternatives 

The impacts on air quality from the Other Action Alternatives (Not Fencing the 

Pattern Areas and Drying Yellowcake On-Site) would not increase the impacts of 

the Proposed Action in terms of duration, significance and scale. Historically, 

vacuum drying of yellowcake in ISR has resulted in no measurable emissions to 

the environment, because the vacuum system is designed to prevent any releases 

(NRC, 2011a). Potential impacts from the yellowcake dryer are also discussed in 

Section 4.17.5.2. 

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4.12 Noise 

4.12.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Section OP 2.8 of the WDEQ-LQD Permit to Mine (LCI, 2011b), and Sections 

3.8, 4.8.1.1, 4.8.1.2, 4.8.1.3, 4.8.1.4, 4.8.2, and 4.8.3 of the NRC SEIS (NRC, 

2011a). The required environmental protection measures are primarily associated 

with wildlife and public and occupational health, which are discussed in Sections 

4.9 and 4.17, respectively. The discussion in this section focuses on off-site 

human receptors. 

The noisiest aspects of the Project would be during Initial Construction and Final 

Reclamation, due to the heavy equipment that would be in use. To reduce the 

noise generated, these activities would primarily occur during daylight hours 

(between 7 a.m. and 5 p.m.), and the 70 dBA 24-hour average sound-energy 

guideline to protect hearing (EPA, 1978) would not be exceeded. Once mining 

operations begin, i.e., pumping and injection of production solutions, the 

operations would continue around the clock, but continuously operating 

equipment (e.g., pumps) would be located inside buildings. During a routine 

night shift, only one employee would be in the field in a light truck to monitor 

equipment. Use of protective devices, such as mufflers and personal hearing 

protection, would be used to maintain noise levels in work areas in the immediate 

vicinity of the equipment below Occupational Health and Safety Administration 

(OSHA) regulatory limits. 

4.12.2 Noise Monitoring 

Because Project noise is not expected to cause any substantial impact, no 

monitoring is planned. 

4.12.3 Impact Significance Criteria 

The 55-dBA guideline, which was established by the EPA’s Office of Noise 

Abatement and Control to protect against activity interference and annoyance 

(1978), was used to assess the significance of noise impacts on the human 

environment. The Rawlins RMP does not specifically state any pertinent factors 

concerning noise with respect to activities such as those of the Proposed Action. 

4.12.4 Noise Impacts from the Proposed Action 

Unlike conventional open-pit mine sites, impacts from increased noise levels are 

minimal at ISR project sites because major dirt-moving equipment is used for 

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only a short period of time as large-scale excavations are not conducted. Noise 

impacts were assessed by comparing background noise levels with projected noise 

levels on-site and off-site during Construction, Operation, and Reclamation. The 

proximity of sensitive receptors was considered in the impact analysis. The 

closest residence, church, or school (i.e., Bairoil) is about 15 miles from the 

northeast Permit Area boundary and would be more than 16 miles from the 

nearest mine unit or the Plant. 

4.12.4.1 Construction 

During Initial Construction, noise would be created due to the use of heavy 

equipment (e.g., dozers, graders, and cranes). Construction would occur for about 

seven months at the beginning of the Project, and would be concentrated near the 

Plant. Average noise levels 50 feet from the heavy construction equipment are on 

the order of 75 to 110 dBA, as shown in Table 4.2-1 of the GEIS (NRC and 

WDEQ, 2009). Beginning at a distance of 50 feet, noise levels diminish by six 

dBA for each doubling of the distance from the source (Golden et al., 1979). The 

Plant is about 1,000 feet from the closest Permit Area boundary (Figure 1.2-2), 

and, given the ambient wind noise (Sections 3.10 and 3.11), the equipment noise 

would be indistinguishable from the wind noise at that boundary. 

There would be negligible adverse effects from on-site noise to the nearest off-site 

receptors due to the considerable distance from the Plant to the nearest populated 

area. Workers commuting to the site and the transport of materials, via truck, 

would be the sources of off-site noise impacting off-site receptors, and these 

would be distributed among the three access routes to the Permit Area. Less than 

ten deliveries per day would be required during the Construction phase, and heavy 

trucks would only pass occupied residences once they reached US-287. This is a 

well-traveled road, and the increase in heavy truck traffic and commuters caused 

by the Project would be approximately two percent (Sections 3.2 and 4.3). This 

incremental increase is not expected to be noticeable. Due to the limited need for 

materials transport and the existing noise created by the highway, adverse effects 

from noise by the Project would be negligible. 

During the Construction for Mine Unit Development, smaller equipment would 

generally be needed, with a corresponding decrease in the noise generated. Onsite measurements of the noise from equipment that would be commonly used at 

the site confirm that the noise levels reduce quickly with distance from the 

equipment, particularly given the generally windy conditions (Figure 4.12-1 and 

Table 4.12-1). 

The above assessment of Construction impacts is in agreement with that in the 

NRC SEIS and includes more specific on-site noise measurements. Section 

4.8.1.1 of the NRC SEIS discusses noise generation during Construction. 

Specifically, noise is generated from the construction equipment and the increased 

traffic to and from the site. The SEIS suggests that the smaller roads would be 

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more impacted than the larger, heavily travelled roads by the increase in traffic, 

and that the construction noise impacts would largely depend on distance from the 

source of the sound (NRC, 2011a). 

Figure 4.12-1 Drilling Rig Noise versus Distance 

4.12.4.2 Operation 

Overall, noise levels during Operation would be expected to be lower than during 

Construction. Noise generated during the Operation phase would be mostly 

attributed to operation of pumps inside the header houses. 

During Operation, periodic truck traffic for material transport, worker commuting, 

and traffic for maintenance and inspections would also contribute noise off-site. 

Less than one delivery per day would be required, and the associated increase in 

truck traffic on US-287 would be less than 0.1 percent, which would not be 

noticeable. Therefore, on-site sources would result in negligible noise increases 

to off-site receptors during this phase. No exceedance of any applicable noise 

criteria for off-site receptors or for on-site personnel is expected during the 

Operation phase. 

The above assessment of Operation impacts is in agreement with that in the NRC 

SEIS and is based on more specific on-site noise measurements. Section 4.8.1.2 

of the NRC SEIS discusses noise generation as a result of the Operation phase. 

Specifically, noise is generated from the increased traffic to and from the site and 

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60

65

70

75

80

85

90

95

100

-200 -100 -50 0 50 100 200

 ← Upwind Feet from Drill Rig Downwind → Noise Level in Decibels

Rig 1

Rig 2

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the processing equipment. The SEIS suggests that the smaller roads would be 

more impacted than the larger, heavily travelled roads by the increase in traffic, 

and that the processing noise impacts would largely depend on distance from the 

source of the sound (NRC, 2011a). 

Table 4.12-1 Field Measurements of Equipment Noise in the 

Permit Area
 

Equipment Location Comment 

Noise Level in 

Decibels 

Low High Average 

Background Northwest HiVol 

Station 

HiVol station off and no other 

equipment running; light breeze 60.1 70.1 65.7 

Pulling 

Unit 

(swabbing) 

100 feet upwind Light breeze blowing east; unit running 60.0 70.0 65.0 

50 feet upwind Light breeze blowing east; unit running 60.0 68.0 65.0 

At operators station 

at end of truck Light breeze blowing east; unit running 66.0 77.0 70.0 

50 feet downwind Light breeze blowing east; unit running 64.0 70.0 67.0 

100 feet downwind Light breeze blowing east; unit running 64.0 67.0 65.0 

Eu 6500is 

Honda 

Generator 

100 feet upwind Light breeze blowing east; unit running 65.0 65.0 65.0 

50 feet upwind Light breeze blowing east; unit running 65.0 65.8 65.2 

At unit Light breeze blowing east; unit running 80.9 

50 feet downwind Light breeze blowing east; unit running 65.0 66.1 65.3 

100 feet downwind Light breeze blowing east; unit running 65.0 65.1 65.0 

110KeV 75 

HP 

Generator 

100 feet upwind Light breeze blowing east; unit running 65.0 65.1 65.1 

50 feet upwind Light breeze blowing east; unit running 65.0 65.0 65.0 

At fender of unit Light breeze blowing east; unit running 76.6 

50 feet downwind Light breeze blowing east; unit running 65.0 65.3 65.0 

100 feet downwind Light breeze blowing east; unit running 65.0 65.2 65.1 

John Deere 

710J 

Backhoe 

(idling) 

100 feet upwind Light breeze blowing east; unit running 65.0 65.0 65.0 

50 feet upwind Light breeze blowing east; unit running 65.0 65.1 65.1 

At unit Light breeze blowing east; unit running 81.5 

50 feet downwind Light breeze blowing east; unit running 65.0 65.7 65.4 

100 feet downwind Light breeze blowing east; unit running 65.0 65.0 65.0 

Water 

Truck 

(idling) 

100 feet upwind Light breeze blowing east; unit running 65.0 65.1 65.0 

50 feet upwind Light breeze blowing east; unit running 65.0 65.8 65.1 

At front left fender Light breeze blowing east; unit running 76.6 

50 feet downwind Light breeze blowing east; unit running 65.0 65.2 65.1 

100 feet downwind Light breeze blowing east; unit running 65.0 65.0 65.0 

* Measurements were performed on February 6, 2009, using a Metrosonics Model db-4000EZ Dosimeter, 

which accurately measures noise between 40 and 140 dBA with a resolution of 0.1 dBA. The instrument was 

checked against a calibrated standard both before and after the spot surveys were completed and found to be 

within 0.1 dB of the standard. The standard had been calibrated within the past year by the manufacturer. 

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4.12.4.3 Reclamation 

During Mine Unit Reclamation and Final Reclamation, noise impacts are 

anticipated to be similar to Construction for Mine Unit Development and Initial 

Construction, respectively. During Mine Unit Reclamation, equipment would be 

used for well abandonment rather than well drilling, with similar or lower noise 

impacts. Truck traffic and heavy equipment activity would be similar to the 

Construction phase due to transportation of waste material to disposal sites and 

decommissioning of structures. 

The above assessment of Reclamation impacts is in agreement with that in the 

NRC SEIS and is based on more specific on-site noise measurements. In Section 

4.8.1.4 of the NRC SEIS, noise generated from Reclamation is expected to be the 

same, or less than, the noise generated during Construction, due to the earth 

moving and deconstruction of the site, and the impacts are not expected to be 

significant (NRC, 2011a). 

4.12.5 Noise Impact from Other Alternatives 

4.12.5.1 No Action Alternative 

Under the No Action Alternative, baseline levels of noise would remain and not 

be increased. Baseline noise levels at the site are described in Section 3.11. 

4.12.5.2 Other Action Alternatives 

The impacts on noise from other alternatives (Not Fencing the Pattern Areas and 

Drying Yellowcake On-Site) would not be appreciably different than those from 

the Proposed Action. The dryer would be located inside the Plant, so no 

additional noise from the dryer operation would be anticipated. Traffic noise 

would be reduced because fewer shipments of dried yellowcake would be needed, 

as compared to yellowcake slurry shipments. 

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4.13 Historic and Cultural Resources 

Discussion of specific locations and characteristics of archaeological resources 

are confidential; disclosure of site locations are prohibited under 43 CFR 7.18. 

Therefore, the information in this section is presented in general terms. 

4.13.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Sections OP 2.4 of the WDEQ-LQD Permit to Mine (LCI, 2011b), Section 3.9 of 

the NRC SEIS (NRC, 2011a), and Condition 9.8 of the NRC License (NRC, 

2011b). 

The best mitigation for known sites is avoidance whenever possible. If avoidance 

of a site is not possible, regulatory requirements exist for mitigation of the 

impacts to a site. Because the locations of the sites eligible for the NRHP are 

already known, the potential impacts on those sites have been evaluated, and 

appropriate mitigation measures have been prepared. 

Site 48SW16604, which is one of three sites determined eligible for the NRHP, 

would be disturbed by Project activities. Therefore, a treatment plan was 

developed in consultation with the BLM, NRC, Wyoming SHPO, the Eastern 

Shoshone Tribe and the Northern Arapaho Tribe (Appendix E of the NRC SEIS 

[NRC, 2011a]). Implementation of the treatment plan would mitigate the adverse 

effects to site 48SW16604. 

Mitigation also includes procedures to be taken after unanticipated discovery of 

archaeological resources. As noted in Section OP 2.4 of the WDEQ-LQD Permit 

to Mine (LCI, 2011b) and the memorandum of agreement among NRC, BLM, 

Wyoming SHPO, the Eastern Shoshone Tribe and Northern Arapaho Tribe 

(Appendix E of the NRC SEIS [NRC, 2011a]), LCI would halt work in the 

immediate area of any such discovery and stabilize the location, so further 

degradation would not occur. An archaeologist would examine and evaluate the 

discovery for significance in accordance with applicable laws and regulations 

including the Archaeological Resources Protection Act, National Historic 

Preservation Act, American Indian Religious Freedom Act, and Native American 

Graves Protection and Repatriation Act. 

4.13.2 Monitoring of Historic and Cultural Resources Impacts 

The restrictions to keep archaeological information confidential are intended to 

prevent intrusion for curiosity or looting. Therefore, information on 

archaeological site boundaries is maintained on controlled maps, and monitoring 

of Project activities near the NRHP sites must be done by an archaeologist. 

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4.13.3 Criteria for Significance Evaluation and Impacts 

Cultural resources are regarded as significant if they are enrolled in, or meet the 

eligibility criteria of, the NRHP. NRHP eligibility criteria are enumerated in Title 

36 CFR Part 60 and are described as follows: 

The quality of significance in American history, architecture, archaeology, and 

culture is present in districts, sites, buildings, structures, and objects that possess 

integrity of location, design, setting, materials, workmanship, feeling, and 

association, and that: 

 are associated with events that have made a significant contribution to the 

broad patterns of our history; or 

 are associated with the lives of persons significant in our past; or 

 embody the distinctive characteristics of a type, period, or method of 

construction, or that represent the work of a master, or that possess high 

artistic values, or that represent a significant and distinguishable entity 

whose components may lack individual distinction; or 

 have yielded, or may be likely to yield, information important in 

prehistory or history. 

To qualify for NRHP eligibility, a property must meet two separate types of 

requirements. It must exhibit integrity of location, design, materials, and related 

criteria, and it must meet one or more of the four additional criteria. The National 

Historic Preservation Act makes it clear that a site need not be of national historic 

significance to be considered eligible (Advisory Council on Historic Preservation, 

2006). Sites of local, state, and regional importance may also be listed and, thus, 

are significant in the legal sense. The phrasing of the National Historic 

Preservation Act of 1966 (as amended) is critical with respect to actual 

management of cultural resources. A site does not have to be included on the 

NRHP to receive protection under the law, but must simply meet the requirements 

of eligibility (Kinneer et al., 2007). 

Under NEPA, impacts to cultural resources may be direct (the result of an action 

that occurs at the same time and place), indirect (the result of an action that occurs 

at a later time or in a different place), or cumulative (incremental, resulting from 

accrued past, present, and reasonably foreseeable future actions). Under Section 

106 of the National Historic Preservation Act, an adverse effect is any impact that 

alters the attributes that qualify the site for inclusion on the NRHP by diminishing 

the integrity of the site. Possible adverse impacts might include physical damage 

or destruction, alternation, deterioration, or modification of original setting. An 

adverse effect on a cultural property would constitute a significant impact unless 

mitigation measures are undertaken to reduce or counter the harm that an 

undertaking would cause. 

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4.13.4	 Historic and Cultural Resources Impacts from the 

Proposed Action 

Direct impacts on cultural resources would come from the surface disturbance in 

the footprint of the Project infrastructure. During the life of the Project, a total of 

approximately 345 acres of the land surface would be disturbed, which is eight 

percent of the 4,254 acres in the total Permit Area. The surface disturbance would 

occur during the Construction phases. There should be no additional surface 

disturbance during the Operation and Reclamation. 

Indirect impacts could result from erosion of soils after surface disturbance and 

vegetation removal. The erosion could result in deposition of material onto 

archaeological sites or removal of soil and subsequent exposure of sites. The 

increased number of people accessing the Permit Area could also lead to intrusion 

onto or looting of sites. 

One prehistoric archaeological site recorded in the Project Area, 48SW16604, 

would incur adverse effects. Site 48SW16604 lies within an area where 

construction related to the well field, an access road, and a pipeline would occur. 

It is anticipated that the entire site would be subjected to surface scraping. As 

described in Section 4.13.1, above, mitigative excavation would take place prior 

to initiation of these activities, and the impacts would therefore not be significant. 

Section 4.9 of the NRC SEIS (NRC, 2011a) discusses the potential impacts to the 

historic and cultural resources in the Permit area. The largest potential for 

impacts occurs during the Construction phase, when resources could potentially 

be excavated or damaged. There is also a potential for the construction process to 

temporarily restrict access to these resources. Management practices that would 

be used during construction with regards to discovery of historical or cultural 

artifacts serve to protect these resources, which would result in a smaller potential 

for significant impacts to the resources (NRC, 2011a). 

4.13.5	 Historic and Cultural Resources Impacts from Other 

Alternatives 

4.13.5.1 No Action Alternative 

Under the No Action Alternative, there would be no impacts to the cultural 

resources related to the Project, although on-going activities, such as livestock 

grazing, could disturb surface archaeological sites. The No Action Alternative 

would not create significant impacts to cultural properties. 

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4.13.5.3 Other Action Alternatives 

Not Fencing the Pattern Areas 

The fences are included within the mine unit boundaries; therefore, this 

alternative would not reduce potential impacts on archaeological resources. This 

alternative would not avoid site 48SW16604, and adverse effects to that site 

would occur. Impacts to site 48SW16604 would not be regarded as significant 

because mitigation would take place prior to the time that impacts are sustained. 

Drying Yellowcake On-Site 

The dryer would be located within the Plant; therefore, this alternative would 

create no additional impacts on the archaeological resources at the Permit Area. 

This alternative would not avoid site 48SW16604, and adverse effects to that site 

would occur. Impacts to site 48SW16604 would not be regarded as significant 

because mitigation would take place prior to the time that impacts are sustained. 

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4.14 Visual and Scenic Resource Impacts 

4.14.1 Agency-Required Measures 

The required environmental protection measures for visual and scenic resources 

are summarized below from Sections 3.10, 4.10.1.1, 4.10.1.2, 4.10.1.3, 4.10.1.4, 

4.10.2 and 4.10.3 of the NRC SEIS (NRC, 2011a). 

The following protection measures are planned to minimize the Project impacts 

on visual and scenic resources. 

 building materials and paint would be chosen to blend with the natural 

environment, according to BLM guidelines; 

 all structures have been designed to be low profile, in order to minimize 

the number of vantage points from which they would be visible; 

 the site would remain clean and well-maintained according to operational 

protocols; and 

 Any necessary night lights would be designed to reduce light pollution. 

4.14.2 Monitoring of Visual and Scenic Resource Impacts 

Since impacts to visual and scenic resources would be negligible, no monitoring 

is currently planned. The Annual Report submitted to NRC and WDEQ would 

document any changes to the status of the visual resources, as necessary. 

4.14.3 Impact Significance Criteria 

The significance of the impacts was evaluated by determining if the visual 

changes would be consistent with the BLM visual resource classification of the 

area, discussed in the Rawlins RMP in the Visual Resource Management Section. 

The Permit Area is within a BLM-designated VRM Class III area and proximal to 

a VRM Class IV area. The management objective for Visual Resource 

Management Class III areas is to, “Partially retain the existing character of the 

landscape. The level of change to the landscape should be moderate. 

Management activities may attract the attention of the casual observer but should 

not dominate the view of the casual observer. Changes should repeat the basic 

natural elements found in the predominant natural features of the characteristic 

landscape” (BLM, 1984). 

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4.14.4	 Visual and Scenic Resource Impacts from the 

Proposed Action 

As outlined below, the nature of the Project impacts would be consistent with the 

visual resource classification of the area. Project facilities would be discernible 

during the day, but would not be a dominant landscape feature to observers 

outside the Permit Area. Night time operations would be minimal. 

4.14.4.1 Construction 

During the seven months of Construction, there would be short-term visual 

impacts due to on-site equipment for the construction of the Project facilities and 

road improvements. This equipment will likely contrast with the forms, lines, 

colors, and textures present in the area, but will only be on-site during 

Construction, not posing a long-term impact on the visual resources of the area. 

Construction activities would result in an increase of vehicles and traffic in the 

area. (The increased potential for dust is discussed in Section 4.11). Vegetation 

disturbance would also take place during Construction. As discussed in Section 

4.8.4.1, the total disturbance acreage during Construction would be on the order 

of 345 acres, which would be scattered throughout the Permit Area. Construction 

activities would occur during the day, so other than occasional lights for safety 

and security, night time impacts would be minimal. 

Section 4.10.1.1 of the NRC SEIS examines the impacts to the visual and scenic 

resources from Construction. The impacts are primarily related to construction 

equipment, the infrastructure being built, land alterations, emissions, and lighting. 

According to the SEIS, the topography is such that most of the infrastructure 

would not be visible from more than one kilometer away. Additionally, the shortterm nature of Construction activities limits the time that the equipment and land 

disturbances would be impacting the visual resources. As such, the impacts to 

visual and scenic resources are not expected to be significant (NRC, 2011a). 

4.14.4.2 Operation 

After Construction, the majority of visual impacts would occur from the facilities 

used during the Operation phase, in particular, the Plant. In general, ISR uranium 

mines can retain the form and line of the existing landscape better than open pit or 

surface mines because less earthwork is necessary. Header houses, wellheads, 

and roads would contribute to the visual impacts, but less so than the Plant. 

Header houses may be visible from the Sooner Road, which is about two miles 

from the site, and the closest road other than the Project access roads. However, 

the header houses, which would be about 12 feet in height at the roof apex and 

painted to blend with the landscape, would only have a weak effect on the form 

and line of the landscape from the key observation points (Appendix I). The 

wellheads, which would be on the order of four feet in height or less, would not 

be noticeable from Sooner Road because they would have weak to no effect on 

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the form, line, color, or texture of the landscape from that distance. Due to the 

height and abundance of sagebrush throughout the Permit Area (Section 3.7), as 

well as the rolling topography, the on-site roads would not be visible unless the 

angle of view is directly in-line with the road. The Plant would be the largest 

building on-site, about 160 feet wide, 260 feet long, with a wall height of 22 feet 

and a peak roof height of 29 feet. 

Figure 4.14-1 is a photograph taken slightly less than 0.25 miles from an existing 

ISR project in Nebraska and helps to visualize how the Permit Area will look. 

However, there are important differences between this project in Nebraska and the 

Project. First, the Plant at the Nebraska site is taller than the Plant would be at the 

Permit Area because of different configurations of the ion exchange columns. 

Second, the vegetation is primarily grassland at the Nebraska site, rather than the 

shrubland at the Permit Area. Figure 4.14-2 is a photograph of the Project Area 

taken from the Sooner road (4.4 miles from the proposed Project). Even though 

there are two white trailers (approximately 4 miles from the photographer and 

approximately 10 feet in height and 20 feet in length) in this photograph, one 

cannot locate them without magnifying the photograph. The trailers are visible 

from the location of the photograph, but are difficult to locate without prior 

knowledge of their location. 

Because of the varying topography of the area, and the presence of the 

Continental Divide Trail and the Rawlins-Ft. Washakie Stage Road in the vicinity 

of the Permit Area, a viewshed analysis was conducted for the Plant using a 

Spatial Analyst add-on to ArcGIS 9.3. The height of the Plant was estimated to 

be ten meters and the viewshed was limited to approximately 25 miles from the 

Plant. Figure 4.14-3 shows the result of the viewshed analysis, illustrating areas 

within 25 miles that are visible from the Plant and from which the Plant would be 

reciprocally visible. The analysis allows identification of any local potential 

visual receptor sites such as the Sooner Road, Wamsutter Crooks Gap Road, the 

Continental Divide Trail, the Rawlins-Ft. Washakie Stage Road, and dispersed 

recreational areas. 

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Figure 4.14-1 Photograph of Existing ISR Project in Nebraska, July 2010 

Figure 4.14-2 Photograph of Project Area from Sooner Road, October 

2011 

Trailers 

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Figure 4.14-3 illustrates that the largest potential impacts from the Plant to the 

local visual resources lie in the southwesterly to southeasterly directions. The 

Plant would be viewable from the Mineral Exploration Road (County Road 63), 

Sooner Road (BLM 3215), and Wamsutter Crooks Gap Road (County Road 23). 

The Plant would potentially be visible from the Continental Divide Trail, but in 

only very limited areas (less than 0.5 miles in total). However, at a distance of 

about 8 miles away, the Plant would not dominate the landscape from the closest 

viewpoints along the Continental Divide Trail. The plant would be visible for 6.9 

miles along the Rawlins-Ft. Washakie Stage Road. Of this total distance, 

approximately half (3.5 miles) is within 6.5 miles of the Plant, and half (3.4 miles) 

is over 17 miles from the proposed Project (Figure 4.14-3). These distances limit 

the impact that Plant can have on the view from the road. The Plant would not be 

visible from Bairoil (the closest town) or Jeffery City (the next closest town). 

Figure 4.14-4 illustrates that most of the areas where visual resources may be 

impacted are within the Visual Resource Inventory Class IV. Although VRI 

classes do not establish management direction, Class IV represents areas with the 

least amount of visual value. 

A Visual Contrast Rating Worksheet was completed for an observation point on 

the Sooner Road (Appendix I). 

As during Construction, night time activities would be minimal. Therefore, other 

than occasional lights for safety and security, there should be only minimal visual 

impact. 

In Section 4.10.1.2 of the NRC SEIS, the NRC discusses that the size or color of 

most of the infrastructure reduces the potential for a significant impacts and the 

visual impacts associated with the Operation phase would be less than the 

Construction phase. (NRC, 2011a). 

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4.14.4.3 Reclamation 

The Reclamation of the Project would not introduce any new visual impacts. 

When Reclamation begins, the impacts are anticipated to be similar to those 

during the Construction because there would be an influx in construction 

equipment (for decommissioning and demolition of certain facilities) and in 

traffic due to the increase in personnel. The visual impact would decline as 

decommissioning progresses. The Project would not cause modifications to 

scenery or topography that would persist after Reclamation. It is unlikely that any 

Reclamation activities would occur at night, so, other than occasional lights for 

security and safety, no impacts are anticipated. 

In Sections 4.10.1.3 and 4.10.1.4 of the NRC SEIS, the Reclamation phase is 

compared to the Construction phase, stating that since the two phases require 

similar equipment and short time frames, the overall visual impact of the phase 

would be minimal (NRC, 2011a). 

4.14.5	 Visual and Scenic Resource Impacts from Other 

Alternatives 

4.14.5.1 No Action Alternative 

The No Action Alternative would present no change to the visual resources of the 

area. 

4.14.5.2 Other Action Alternatives 

If no fences were installed around the pattern areas, there would be a slight 

reduction to the visual impact of the Project. However, fences are not likely to be 

more visible than the wellheads, which may be visible, but would not dominate 

the landscape or distract potential observers from the natural landscape. In 

addition, the types of fences around the pattern areas are typical of most fences in 

the vicinity. Since the dryer for the Drying Yellowcake On-site alternative would 

be inside the Plant, there would be minimal additional impact to the visual 

resources. 

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4.15 Socioeconomic Conditions 

4.15.1 Agency-Required Measures 

While there are no agency-required measures related to socioeconomic 

conditions, LCI and LCI’s contractors and subcontractors would be encouraged to 

deliver construction materials “Free on Board” to the County in which the 

materials would be used to help ensure that the sales tax would be properly 

allocated and paid to the County where construction and related impacts would 

occur. 

In addition, LCI has commitments and initiatives to minimize socioeconomic 

impacts. LCI would support local hiring and procurement to the extent 

practicable and would continue working with Sweetwater and Carbon Counties on 

topics of interest. 

4.15.2 Monitoring of Socioeconomic Impacts 

Significant socioeconomic impacts are not anticipated, so no monitoring is 

planned. 

4.15.3 Impact Significance Criteria 

In accordance with the Rawlins RMP Management Goals, the Proposed Action 

provides an opportunity to develop a national energy source on BLMadministered lands while not interfering substantially with development of other 

resources, such as tourism, and provides for mitigation of impacts to development 

of other resources (e.g., grazing and wildlife). The following criteria were used to 

assess the significance of socioeconomic impacts to ensure the continued viability 

of the local and regional communities: 

 An increase of the local and regional population that would strain the 

ability of communities and/or counties to provide adequate housing and 

services; 

 Increasing demands on government expenditures that would inhibit the 

maintenance and/or provision of infrastructure and services; 

 An increase in the local or regional cost of living; 

 A reduction in socioeconomic viability of local and regional communities; 

and conversely, 

 An increase in government revenues that would offset increased demands 

for services; and 

 An improvement in socioeconomic viability due to indirect economic 

activity (e.g., purchase of local goods). 

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Socioeconomic impacts would occur during all phases of the Project, and LCI has 

met with county and local governments to help ensure a cooperative effort to 

sustain and improve the economies and conditions. The potential impacts to 

demographics, economic trends and characteristics, and infrastructure and 

services are discussed in the following sections by subject. Each subject is then 

described by Project phase unless the socioeconomic impact is similar throughout 

the Project phases or is generally evaluated over the life of the Project. 

4.15.4 Demographic Impacts from the Proposed Action 

4.15.4.1 Construction 

The local population is anticipated to increase as a result of increased employment 

opportunities generated both directly and indirectly by the Project. Direct 

employment during Initial Construction is anticipated to peak at 94 employees. 

It is assumed the majority of the workforce would come from outside the region. 

Although many towns are within the region, much of the workforce is anticipated 

to reside in larger, more economically diversified population centers, such as 

Rawlins and Casper. The duration of Construction would be less than one year. 

If the majority of the Construction workforce is from outside of the region, 

demographics would change. If the majority of the Construction workforce is 

from within the region, demographic impacts would be negligible. 

Indirect employment is estimated by assuming an employment multiplier. 

Assuming an employment multiplier of 0.7 for the milling/mining industry (NRC, 

2011a), an estimated 65 to 66 additional jobs would be generated (i.e., 94 

positions multiplied by 0.7). 

The total of direct and indirect employment would range from 159 to 160 

positions. Assuming an average of 2.5 people per household, the population of 

the region would increase by 397 to 400 people (i.e., 159 to 160 positions 

multiplied by 2.5). However, since a portion of the Construction workforce 

already resides in the region, the population increase would be less than this 

estimate. In an extreme case, if the population did increase by 397 to 400 people, 

in Rawlins alone, the population would increase by four to five percent. 

Realistically, migrants would be dispersed throughout other communities in the 

region as well. 

The assessment of Initial Construction impacts in this EIS is similar to that of the 

Construction assessment in the NRC SEIS with more focus on whether the 

workforce would come from outside or within the region. Section 4.11.1.1 of the 

NRC SEIS discusses how in the short-term, the influx of Construction employees 

would likely not significantly impact the demographics of the region. Since the 

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Construction phase is for a short time, the long-term impact would be negligible, 

and the overall impact would be small (NRC, 2011a). 

During Mine Unit Development, direct employment is expected to average 106 

employees. Of these 106 employees, about 54 are anticipated to have been 

employed during Initial Construction. The remaining 52 employees would be 

technical staff trained in health physics, chemistry, geology, hydrogeology, and 

engineering and would likely come from outside the region. As during Initial 

Construction, the Mine Unit Development workforce is anticipated to reside in 

larger population centers that offer more amenities and economic diversity. 

Because the majority of the workforce would work through Initial Construction 

and Mine Unit Development, the demographic change during Mine Unit 

Development would be less than during Initial Construction. Overall, the number 

of employees would increase by 12 employees from Initial Construction (94 

employees) to Mine Unit Development (106 employees). However, as noted in 

the paragraph above, 52 of the average 106 employees would likely be hired from 

outside of the region for their technical skills. Therefore, it is deduced that as 

little as 12 people to as many as 52 people would be new, direct employees of the 

Project during Mine Unit Development. Assuming an employment multiplier of 

0.7 for the milling/mining industry (NRC, 2011a), an estimated 8 to 37 indirect 

jobs would be generated (i.e., 12 to 52 positions multiplied by 0.7). 

The total of additional direct and indirect employment from Initial Construction to 

Mine Unit Development would range from 20 to 89 positions. Assuming an 

average of 2.5 people per household, the population of the Project region would 

increase by 50 to 222 people (i.e., 20 to 89 positions multiplied by 2.5). In an 

extreme case, if the population did increase by 50 to 222 people in Rawlins alone, 

the population would increase by 0.5 to 2.7 percent. Realistically, migrants would 

be dispersed throughout other communities in the region as well. 

The Mine Unit Development assessment in this EIS is similar to that of the 

Operation assessment in the NRC SEIS with more focus on whether the 

workforce would come from outside or within the region. Section 4.11.1.2 of the 

NRC SEIS (NRC, 2011a) describes how the workforce associated with the 

Operation phase might change the socioeconomic conditions. However, because 

of the small number of Operation employees, the impact to demographics is not 

expected to be significant (NRC, 2011a). 

4.15.4.2 Operation 

Demographics are not anticipated to change from Mine Unit Development to 

Operation. 

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4.15.4.3 Reclamation 

Demographics are not anticipated to change from Operation to Mine Unit 

Reclamation. 

Final Reclamation would require a similar, if not the same, workforce of Initial 

Construction. As such, demographics are not anticipated to change until Project 

closure. At that time, the Project workforce would likely be drawn to other ISR 

facilities or other regional extractive industries. 

The overall assessment of Final Reclamation in this EIS is similar to the 

assessment of Reclamation in the NRC SEIS with more focus on where the 

workforce could go after Project Closure. Section 4.11.1.4 of the NRC SEIS 

discusses how in the short-term, the influx of Reclamation employees could 

impact the region. However, since it is for a short time, the long-term impact to 

demographics would be negligible (NRC, 2011a). 

4.15.5	 Revenue and Taxation Impacts from the Proposed 

Action 

The Project would contribute to the local economy through taxes generated, job 

creation, employee wages, and direct and indirect economic activity in the local, 

regional, and national economies. 

4.15.5.1 Gross Domestic Product 

The Project would contribute to Wyoming’s dominant GDP industry: mining. 

Using February 2010’s market price of U3O8 (about $42 per pound), the Project 

would contribute $360,000,000 to the nation’s GDP. The price increased to about 

$73 per pound at the beginning of 2011, and the price has been about $52 per 

pound in the first part of 2012. The Project would boost the immediate area’s 

diversity and economic health. 

The NRC SEIS does not specifically address the nation’s or the State’s GDP. 

4.15.5.2 Revenue and Taxation 

The purchases made by and the taxes collected from the Project would generate 

revenue. The primary internal costs of the Project would include: 

 capital costs associated with obtaining claims and regulatory approvals, 

including permits, and environmental studies; 

 capital costs of facility construction; 

 operation and maintenance costs; 

 costs of groundwater restoration; 

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 costs of facility decommissioning, including radiological decontamination; 

and 

 costs of surface reclamation. 

These estimated costs are provided in Table 4.15-1. The total Project costs are 

estimated at $225 million, not including local, state and federal taxes. A portion 

of this would be spent in the local area (Rawlins) for diesel fuel, propane, and 

miscellaneous supplies and repairs. This would be considered a positive impact 

to the local economy. The majority of supplies would come from Casper. 

Oxygen and CO2 would come from Wyoming or Colorado, and soda ash would 

come from Green River, Wyoming. Major construction materials would be bid 

out regionally, with a large portion anticipated to come from the ColoradoWyoming-Utah region. 

Table 4.15-1 Estimated Internal Project Costs 

Item Present Worth 

(US dollars x 1,000) 

Obtaining the right to mine (claims and permits) 13,000 

Facility construction 68,000 

Operation and maintenance 74,000 

Groundwater restoration 13,000 

Decommissioning (including decontamination) 12,000 

Surface reclamation 3,000 

The Project would contribute substantially to the local and state economies in the 

form of tax revenues generated. Tax revenues from the Project would depend on 

the production of U3O8 and the cost of production. Future tax revenues are 

dependent on uranium prices, which may considerably fluctuate. To the extent 

that uranium prices remain at current levels, uranium production would contribute 

significantly to local tax revenues. 

As shown in Table 4.15-2, tax revenues generated from the Project would include 

property taxes and ad valorem (gross products) taxes in Sweetwater County, 

severance taxes for the State of Wyoming, and federal income taxes. Equipment 

would be registered at the County Assessor's Office and a discount (50 percent) 

would be applied to the market value, then 11.5 percent of the adjusted value 

would be taxed at a rate of 63.088 mills (NRC, 2011a). This property tax revenue 

would accrue to Sweetwater County. Since the Permit Area is located in 

Sweetwater County, ad valorem taxes would also accrue in Sweetwater County. 

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Table 4.15-2 Estimated Tax Revenues Based on Project’s Annual
	

Production
 

Year U3O8 

Production 1 

Estimated 

Federal 

Income 

Taxes 

Wyoming 

Severance 

Taxes 

County Ad 

Valorem 

Taxes 

County 

Property 

Taxes 

1 45,000 

2 1,000,000 900,000 1,600,000 300,000 

3 1,000,000 9,000,000 1,000,000 1,900,000 300,000 

4 1,000,000 10,000,000 1,000,000 2,000,000 300,000 

5 1,000,000 10,000,000 1,000,000 2,000,000 250,000 

6 1,000,000 10,000,000 1,000,000 2,000,000 250,000 

7 1,000,000 10,000,000 1,000,000 2,000,000 100,000 

8 400,000 3,000,000 700,000 900,000 50,000 

9 50,000 

Total 6,445,000 52,000,000 6,600,000 12,400,000 1,600,000 1 Assuming a realized sales price of 60.00 US dollars per pound U3O8 

Section 4.11.1 of the NRC SEIS discusses the potential impacts to taxes and 

revenue. The region would benefit slightly from the small increase in spending 

from the additional workforce, however, this impact is expected to be small. The 

State of Wyoming would benefit from mining taxes on the Project, but this is also 

expected to be fairly small relative to the total State revenue (NRC, 2011a). 

A four-percent severance tax of taxable market value would be levied by the State 

of Wyoming’s Mineral Tax Division of the Department of Revenue. Assuming 

an estimated production of 8,000,000 pounds of U3O8 over the life of the Project 

and a market value of $60 per pound of U3O8, the severance tax revenues 

generated from the Project would equal $19,200,000. 

Other tax revenues include sales, use, and lodging taxes. These amounts would 

represent an increase in local revenues throughout the region. The Project's 

operation and its employees would contribute to local, regional, and state 

revenues through the purchase of goods and services and through the taxes levied 

on such goods and services. Sales taxes and increased demand for goods and 

services would support the local economy. Additional spending would result 

from payrolls and other on-going expenditures. Expenditures generally multiply 

as the monies are circulated throughout the community several times. 

Money would be reinvested in the community as the Project replenishes its 

resources and operates throughout the life of the mine, including costs associated 

with exploration and evaluation, maintenance, sustaining capital, and routine 

operation. Increases in taxes and revenues would provide counties and 

communities with more discretionary dollars to develop infrastructure and support 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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the population. However, short-term budgetary impacts to local governments 

would occur, due to population growth and its effects on housing and local 

infrastructure and services. Receipt of taxes generally lags one year behind 

production; therefore, affected counties and communities would not receive any 

funds until two years after the beginning of the Construction phase. 

4.15.6	 Labor, Employment and Income Impacts from the 

Proposed Action 

Nationally, the Project would reduce dependence on foreign sources of uranium 

while helping to maintain a viable domestic workforce with the necessary 

technical skills to recover uranium resources. Due to market conditions over the 

past 20 years, the technical expertise required to recover uranium has declined. 

LCI estimates that less than 20 engineers and 20 geologists in the US have 

adequate experience to successfully and safely operate an ISR uranium facility. A 

large percentage of these experts are at retirement age. 

The Project would increase the number of jobs and employment in the counties of 

interest without federal assistance. Given the existing economic downturn and 

associated unemployment, the Project would increase regional construction and 

service industry jobs. Throughout its life, the Project would support about 106 

direct jobs locally and a number of indirect jobs. However, similar to tax 

revenue, labor and employment would depend on the amount of U3O8 produced. 

Federal income tax would be collected from the Project’s workforce. Since 

Wyoming does not tax personal income, local, regional, and state income benefits 

would be related to the purchase of goods and services and through the taxes 

levied on such goods and services. As previously discussed, sales and use taxes 

and increased demand for goods and services would support the local economy. 

Additional spending would result from payrolls and other on-going expenditures. 

The economic benefit of expenditures related to the Project would magnify as 

funds are dispersed throughout the communities. 

4.15.6.1 Construction 

During Construction, the Project would require approximately 70 independent 

contractors, 24 LCI employees, and other intermittent contract employees at the 

Permit Area. Once the Plant is constructed, the number of independent 

contractors would be reduced to 30 drillers in order to focus on Mine Unit 

Development. In total, the Project would employ 94 people throughout 

Construction. The estimated direct-hire labor force is presented and described in 

Table 4.15-3. As previously discussed, the total of direct and indirect 

employment is estimated to range from 159 to 160 positions. 

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Table 4.15-3 Estimated Labor and Employment 

Project Phase/Stage Labor Employees 

Drill contractors (10) 30 

LCI construction employees 7 

Initial Construction Stage Other LCI employees (samplers, 

geologists, supervision, drilling support) 17 

Plant construction contractors 40 

Total 94 

Mine Unit Development Stage, 

Operation Phase, Mine Unit 

Reclamation Stage 

LCI construction employees 7 

LCI employees (Plant & mine units) 69 

Drilling contractors 30 

Total 106 

Final Reclamation Stage LCI employees 11 

Total 11 

Local contractors would be hired, as available, and local building materials and 

building supplies would be used to the extent practicable. Many of the workers 

are anticipated to come from Casper. Some workers may commute from Casper 

on a daily basis; others coming from Casper would stay in temporary 

accommodations during the week and commute back to Casper on the weekend. 

Construction workers coming from outside the region would likely use local 

temporary housing (e.g., apartments, hotels, motels, trailers, RVs). Some workers 

would commute to and from their permanent residence on a daily basis if within a 

one-hour drive of the Permit Area. 

The mean earnings rate for construction workers was $26,239 per year in 2008 

(Wyoming Department of Employment, 2009). The mean earnings rate for 

natural resources and mining workers was $54,183 per year in 2008. Workers 

would be paid wages typical of the area. 

The Initial Construction assessment in this EIS is similar to that of the 

Construction assessment in the NRC SEIS. Section 4.11.1.1 of the NRC SEIS 

discusses how in the short-term, the influx of Construction employees could 

impact the income and employment in the region. However, since it is for a short 

time and the pay rates would be typical of the region, the long-term impact would 

be negligible (NRC, 2011a). 

During Mine Unit Development, the Project would require an additional 52 LCI 

employees. In total, approximately 106 people (30 contract drillers and 76 LCI 

personnel) would be employed. LCI personnel would include: Project and 

operation managers; a Project engineer; a chief site geologist; a drill foreman; a 

casing crew; a restoration engineer and crew; a construction foreman and crew; 

geologists; a secretary; personnel responsible for environmental, health, and 

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safety related tasks; a plant manager; plant operators; equipment operators; an 

electrician; a chemist; and lab technicians. 

Impacts to income during Operation would be similar to those of Construction. 

Technical LCI employees would average approximately $45,000, with an 

estimated total annual payroll of $2,900,000. 

The combination of Mine Unit Development, Operation, and Mine Unit 

Reclamation is similar to that of the Operation phase evaluated in the NRC SEIS. 

Section 4.11.1.2 of the NRC SEIS describes how the workforce associated with 

the Operation phase might change the income and employment in the region. 

However, since it is for a short time and the pay rates would be typical of the 

region, the long-term impact would be negligible (NRC, 2011a). 

4.15.6.2 Operation 

The labor, employment, and income impacts during the Operation phase are not 

anticipated to differ from Mine Unit Development. 

4.15.6.3 Reclamation 

The labor, employment, and income impacts during Mine Unit Reclamation are 

not anticipated to differ from the Operation phase. 

During Final Reclamation, technical staff would decrease to less than the Initial 

Construction staff (11 LCI employees). Additional contract employees would be 

hired as necessary during Project decommissioning. The income levels during 

Final Reclamation are anticipated to be similar to those during Initial 

Construction. 

The staff would decrease as the Project nears completion. At that time, the 

Project workforce would likely apply their skills at other ISR facilities or 

extractive industries. 

Final Reclamation in this EIS is similar to that of the Reclamation phase 

evaluated in the NRC SEIS. Section 4.11.1.4 of the NRC SEIS discusses how, in 

the short-term, the influx of Reclamation employees could impact the income and 

employment in the region. However, because of the short duration and pay rates 

typical of the region, the long-term impact would be negligible (NRC, 2011a). 

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4.15.7	 Cost of Living and Housing Impacts from the Proposed 

Action 

Due to the size and duration of the Project as well as the anticipated population 

centers of residence for personnel, impacts to the cost of living are not 

anticipated. 

The increase in population directly and indirectly caused by the Project would 

increase regional housing demand. In the recent past, housing availability has 

increased in Casper and Rawlins, where the majority of the Project’s workforce is 

anticipated to live. 

Since 2007, Wyoming’s active residential real estate markets have eased 

somewhat with increased inventories and lower transactions in many communities 

(EAD, 2010e). As of January 13, 2010, 504 homes were listed under the MultiListing Service in Casper (Glasspoole, T. GRI, CRS Sales Associate/Owner, 

RE/MAX, The Group. Personal communication. January, 2010.). This total does 

not include the homes that were for sale by owners, without the aid of a listing 

agency. The largest rental agency in Casper, Casper Rental Agency, had a total of 

173 vacant rental properties on January 12, 2010. Rawlins had at least 88 homes 

on the market on January 25, 2010 (Shepard, A. Broker/Owner, ERA Shepard & 

Associates. Personal communication. January, 2010.). This total does not include 

homes for sale by owners, without the assistance of a listing agency. Rawlins had 

a total of 30 vacant rental units on January 16, 2010 (based on a count of rentals 

advertised in the Rawlins Daily Times and information from contacting rental 

agencies). Additionally, both Casper and Rawlins have a large number of 

residential lots for sale. Therefore, the minimum number of rentals and homes 

available as of January 2010 in Casper and Rawlins is 795. 

Data were not collected for other communities within driving distance from the 

Permit Area, such as Wamsutter, Bairoil, and Jeffrey City. 

4.15.7.1 Construction 

As previously noted, 94 people would be directly employed by the Project during 

the Initial Construction stage. Indirect and direct employment by the Project 

would range from 159 to 160 positions. Therefore, as many as 160 housing units 

would be required during the Initial Construction stage. However, a portion of 

the workforce already resides in the area. 

The Plant construction workforce and intermittent contractors are anticipated to 

commute from their residences within the region or use local temporary housing 

(e.g., apartments, hotels, motels, trailers, RVs). The remainder of the Initial 

Construction workforce (54 personnel) would likely support activities of the Mine 

Unit Development stage, Operation phase and Reclamation phase; therefore, the 

majority of the workforce would likely rent or purchase houses. 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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Initial Construction in this EIS is similar to that of the Construction phase 

evaluated in the NRC SEIS. Section 4.11.1.1 of the NRC SEIS discusses how in 

the short-term, the influx of Construction employees could impact the demand for 

rental units in the region. However, since it is for a short time, the long-term 

impact would be negligible (NRC, 2011a). 

Upon starting Mine Unit Development, the majority of the workforce (54 

personnel) would already have established residence in the region during Initial 

Construction. An additional 12 to 52 technical LCI employees would likely move 

from outside of the region. Thus, 20 to 89 housing units would be required to 

support the direct (12 to 52 employees) and indirect (8 to 37 employees) 

employees of the Project. 

The combination of Mine Unit Development, Operation, and Mine Unit 

Reclamation in this EIS is similar to that of the Operation phase evaluated in the 

NRC SEIS. Section 4.11.1.2 of the NRC SEIS describes how the workforce 

associated with the Operation phase might increase the demand for permanent 

housing in the region. However, since there is a small number of Operation phase 

employees and the housing development in the region has kept pace with the 

population changes, the impact is not expected to be significant. 

4.15.7.2 Operation 

The cost of living and housing impacts during Operation are not anticipated to 

differ from those during Mine Unit Development. 

4.15.7.3 Reclamation 

The cost of living and housing impacts during Mine Unit Reclamation are not 

anticipated to differ from the Operation phase. 

The housing required during Final Reclamation would be similar to that required 

during Initial Construction. The technical staff from Mine Unit Development, 

Operation, and Mine Unit Reclamation would be reduced and would likely apply 

their skills at other nearby ISR facilities or extractive industries. Meanwhile, the 

contract employees hired for deconstruction and decommissioning would likely 

commute from their residences within the region or use local temporary housing 

(e.g., apartments, hotels, motels, trailers, RVs). Similar to the reduced technical 

staff at the beginning of the Final Reclamation stage, the LCI employees and 

contractors that remain at the time of Project completion would likely apply their 

skills at other nearby ISR facilities or extractive industries. 

Final Reclamation in this EIS is similar to that of the Reclamation phase 

evaluated in the NRC SEIS. Section 4.11.1.4 of the NRC SEIS discusses how in 

the short-term, the influx of Reclamation employees could impact the demand for 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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rental units in the region. However, since it is for a short time, the long-term 

impact would be negligible (NRC, 2011a). 

4.15.8	 Impacts to Infrastructure and Services from the 

Proposed Action 

With a population influx, improvements to infrastructure and services may be 

required sooner than anticipated and, if so, would have budgetary effects on local 

governments. Increases in taxes and revenues would provide counties and 

communities with funding to develop and/or maintain infrastructure and to 

support the increased population. 

Due to the taxing system, impacted localities may not receive adequate funds in a 

timely manner to keep pace with increased demand. As previously noted, receipt 

of taxes generally lags one year behind production; therefore, affected counties 

and communities would not receive funds until two years after construction 

begins. Therefore, the following discussion is based on the impacts from the 

Project as a whole to specific items (e.g., education) rather than the individual 

phases of the Project. 

Additionally, the distribution of increased tax revenue generated by the Project 

may not accrue or be proportionately distributed to the localities experiencing 

increased demand. Tax revenue would accrue mainly in Sweetwater County and 

in the State, even though the majority of the Project’s workforce is anticipated to 

reside in Carbon and Natrona counties. Similarly, communities experiencing 

increased infrastructure and service demand may not receive a proportionate level 

of tax increase as sales tax tends to accrue in the larger population centers with 

more amenities. For example, even though Sweetwater County communities near 

the Permit Area would experience increased demand on infrastructure and 

services, a large portion of goods and services would be purchased in Carbon and 

Natrona counties. However, the costs associated with increased demand of public 

facilities and services are expected to be minimal. 

4.15.8.1 Education 

The Project’s peak direct employment would be about 106 employees, with an 

indirect employment of 74 people. Assuming each employee has a family that 

would move from outside of the region, the children of about 180 families would 

be enrolled in the region’s school districts. If an average person has a working 

career of 45 years and school-age children reside in the household for 

approximately 17 years, then 38 percent of the employee’s working career would 

be associated with school-age children. Assuming each family has 1.86 children 

(US Census Bureau, 2004), the following equation would be used to estimate the 

number of school-age children: 

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The Project region’s school capacity is sufficient for a conservative estimate of an 

additional 127 students. In 2008, Bairoil enrolled 5 elementary school students; 

Wamsutter enrolled 83 elementary and middle school students; Rawlins enrolled 

1,569 elementary, middle, and high school students; and Casper enrolled 10,786 

elementary, middle, and high school students. Thus, an increase of 127 students 

in these schools would increase student enrollment by 1.0 percent. Impacts to 

education would likely be minimal because: a portion of the anticipated families 

already reside in the region; the majority of the families are anticipated to reside 

in Rawlins or Casper, which would easily accommodate this increase; and the 

schools that could be impacted (in Bairoil and Wamsutter) already use Rawlins’ 

schools for at least high school if not middle school and high school. In addition, 

the regional school districts have accommodated more students than those 

enrolled in 2008. For example, Sweetwater School District One’s enrollment was 

5,033 students in 2009 and was 6,127 students in 1991 (Wyoming Department of 

Education, 2010). Carbon County School District One’s enrollment was 1,803 

students in 2009 and was 2,420 students in 1991. Natrona School District One’s 

enrollment was 11,743 students in 2009 and was 13,100 students in 1994. 

According to Section 4.11.1.2.6 of the NRC SEIS, the Operation phase may have 

a small impact to the number of students in the schools. (The combination of the 

Mine Unit Development stage, Operation phase, and Mine Unit Reclamation 

stage is similar to that of the Operation phase evaluated in the NRC SEIS.) 

However, the number is expected to be so small that the schools would not 

experience any significant changes (NRC, 2011a). 

4.15.8.2 Health Care 

Basic medical and emergency services that may be required in the event of an 

accident would be available at the Permit Area. Potential impacts to local health 

services, such as hospitals or emergency clinics, would be minimal. Local 

communities would need a minimal increase in emergency response and medical 

treatment capabilities due to the small risk of industrial accident of the Project. 

Existing emergency response and medical treatment capabilities handle industrial 

accidents similar to those that could occur at the Permit Area; and a variety of 

industrial and hazardous materials are transported on Interstate 80 through 

Rawlins, which is about a 50-mile drive southeast of the Permit Area. Therefore, 

basic services are already established that can support the Project. 

According to Section 4.11.1 of the NRC SEIS, the demand for health services 

would increase with the influx of new employees. However, the small number of 

workers would have a small influence on the region (NRC, 2011a). 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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4.15.8.3 Law Enforcement and Fire Protection 

Law enforcement and fire protection services have adequate capacity for the 

increased population. 

4.15.8.4 Communications and Utilities 

Communication services have adequate capacity for the increased population. 

An overhead electrical power line would be constructed to supply power for the 

Project at the Permit Area. The power line would connect to the pre-existing 

transmission line located directly west of the Permit Area. In addition, water 

supply and some waste disposal facilities for the Project would be developed by 

LCI due to the lack of such facilities in the vicinity of the Permit Area. 

The communities of interest have ample utilities to accommodate the increase in 

population. However, the Rawlins utility infrastructure is in need of repair. With 

the population influx, improvements to public water, sewer, and street facilities 

and services may be required sooner than anticipated and would have budgetary 

effects on the local government. 

4.15.8.5 Recreation 

The population increase would directly affect recreational use and participation. 

Since the current recreational infrastructure and regulatory oversight are adequate 

to accommodate the population increase, the revenue generated by the increased 

recreation would benefit the local communities and the State. 

In addition, data collection and increased economic activity would enhance 

cultural, educational, and recreational opportunities. The social, cultural, and 

environmental data collected for the Project would enhance the understanding and 

value of the Permit Area and its environs. 

As discussed in Section 4.2, impacts to recreational land use would be negligible 

due to the short-term duration of the Project and the small area of disturbance 

and/or restriction. For instance, hunting, which is the primary recreational 

activity, would be restricted to areas outside fenced portions of the Permit Area 

for safety reasons, but would not be permanently affected, and may be improved 

due to wildlife habitat reclamation and improved transportation routes. 

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4.15.9 Socioeconomic Impacts from Other Alternatives 

4.15.9.1 No Action Alternative 

Under the No Action Alternative, the local, regional and national socioeconomics 

would reflect the baseline conditions described in Section 3.14. 

4.15.9.2 Other Action Alternatives 

Not Fencing the Pattern Areas would minimally reduce the Project’s expenditures 

(thus, revenue and taxation) and employment. The overall socioeconomic impact 

of Drying Yellowcake On-Site would be limited compared to the socioeconomic 

impact of the Project as a whole. 

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4.16	 Environmental Justice 

Environmental justice is the fair treatment and meaningful involvement of all 

people, regardless of race, color, national origin, or income. In 1994, President 

Bill Clinton passed Executive Order 12898 to address environmental justice 

through federal agencies. 

Per this executive order and subsequent guidelines, this section identifies known 

minority, low-income, and Tribal populations within the socioeconomic study 

area, evaluates whether or not these populations may have disproportionately high 

or adverse human health or environmental effects from the Project, and discusses 

the manner in which all populations would be treated fairly and meaningfully 

involved. 

The results of the following assessment are in general agreement with the Section 

4.12 of the NRC SEIS which determined that the environmental and 

socioeconomic impacts of the Proposed Action would not disproportionately 

affect the populations of concern. The NRC SEIS also evaluated potential 

radiological impacts from subsistence consumption of fish and wildlife as part of 

traditional lifestyles and concluded there would not be any disproportionate 

impacts (NRC, 2011a). 

4.16.1	 Agency-Required Measures 

The need for protective measures of environmental justice impacts is not 

anticipated. 

4.16.2	 Monitoring of Environmental Justice Impacts 

Monitoring of environmental justice impacts is not anticipated. 

4.16.3	 Environmental Justice Impacts from the Proposed 

Action 

4.16.3.1	 Identification of Minority, Low-Income, and Tribal 

Populations 

Minority Populations 

Consequent to Executive Order 12898, the Interagency Working Group on 

Environmental Justice was created, comprising twelve federal agencies and 

several White House offices (EPA, 2010b). The Interagency Working Group 

developed guidance on key environmental justice terms. The Interagency 

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Working Group defines a minority as an individual who is a member of the 

following races and ethnicity: American Indian or Alaskan Native; Asian or 

Pacific Islander; Black, not of Hispanic origin; or Hispanic (Council on 

Environmental Quality, 1997). A minority population is a population in which: 

the minority population represents more than 50 percent of the total population; or 

the minority to general population ratio of the affected area is meaningfully 

greater than the minority to general population ratio of the larger, general area. A 

minority population may be either a group of individuals living in geographic 

proximity to one another, or a geographically dispersed/transient set of 

individuals (e.g., migrant workers or Native Americans), where either type of 

group experiences common conditions of environmental exposure or effect. A 

minority population also exists if there is more than one minority group present 

and the minority percentage, as calculated by aggregating all minority persons, 

meets one of the above-stated thresholds. 

As shown in Table 4.16-1, at least 90 percent of the population of each county of 

interest and the State of Wyoming was white in 2000, with the exception of 

Fremont County. Fremont County’s population was 77 percent white and 20 

percent American Indian or Alaskan Native (largely from the Wind River Indian 

Reservation). The communities of interest were also predominantly white. The 

white population in Bairoil, Wamsutter, Jeffrey City, and Casper represented 94 

to 100 percent of the total population. Rawlins had the lowest percentage (86 

percent) of white population; the general remainder of Rawlins’ population was 

either some other race (eight percent) or more than two races (three percent). 

As noted in Section 3.14, six percent of the State’s population was of Hispanic or 

Latino ethnicity in 2000. About four to five percent of Fremont and Natrona 

counties’ populations were of Hispanic or Latino ethnicity, whereas Sweetwater 

and Carbon counties’ Hispanic or Latino ethnic populations were 9 and 14 

percent, respectively. The Hispanic or Latino population in Bairoil, Jeffrey City, 

and Casper represented no more than five percent of the total population. 

Wamsutter’s and Rawlins’ Hispanic or Latino populations were 13 and 21 percent 

of the total population, respectively. 

In 2000, within the socioeconomic study area, the population of minorities was 

less than 50 percent of the total population. In addition, the minority to general 

population ratio of the affected area was comparable (within 20 percent) to the 

minority to general population ratio of the larger, general area. Therefore, 

disproportionately high or adverse impacts to any minority race or ethnicity are 

not anticipated. 

Low-Income Populations 

Low-income populations are identified with the annual statistical poverty 

thresholds from the Bureau of the Census’ Current Population Reports, Series P60 on Income and Poverty (Council on Environmental Quality, 1997). The 

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thresholds represent the minimal annual cash income to support various-sized 

families, and are updated annually to account for inflation. 

As shown in Table 4.16-2, from zero to 13 percent of families and from four to 

17 percent of individuals within the places and areas of interest lived in poverty in 

1999. These percentages are similar (within 20 percent) to the State-wide average 

of 8 and 11 percent for families and individuals below the poverty level, 

respectively. Based on the data above, low-income populations are not 

anticipated to be disproportionately affected by the Project. 

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Table 4.16-1 Populations by Race and Ethnicity, 2000 

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Table 4.16-2 Low Income Populations, 1999 

Place 

Families Individuals 

Families 

Below 

Poverty Level 

Total 

Families 

Individuals 

Below 

Poverty Level 

Total 

Individuals 

# % # % # % # % 

State of Wyoming 10,585 8 131,508 100 54,777 11 493,782 100 

Sweetwater County 548 5 10,194 100 2,871 8 37,613 100 

Bairoil 2 8 25 100 4 4 97 100 

Wamsutter 8 11 70 100 28 11 261 100 

Carbon County 411 10 4,180 100 1,879 12 15,639 100 

Rawlins 235 10 2,259 100 1,114 13 8,538 100 

Fremont County 1,267 13 9,495 100 6,155 17 35,804 100 

Jeffrey City 1 0 0 27 100 7 7 106 100 

Natrona County 1,548 9 17,772 100 7,695 12 66,533 100 

Casper 1,122 8 13,238 100 5,546 11 49,644 100 

* US Census Bureau, 2000 1 Census Designated Place 

Tribal Populations 

Table 4.16-1 shows the American Indian and Alaskan Native populations within 

the socioeconomic study area. Fremont County has 63 percent of the American 

Indian and Alaskan Native population of the State of Wyoming. A large portion 

of the tribal population in Fremont County resides at the Wind River Indian 

Reservation, which is centered approximately 75 miles north-northwest of the 

Permit Area and would not be directly impacted by the Project. The tribal 

populations in other places and areas of interest represent less than two percent of 

the total populations. As such, tribal populations would not be disproportionately 

or adversely impacted by the Project. 

4.16.3.2 Fair Treatment and Meaningful Involvement 

To ensure environmental justice, all people are and would be treated fairly and 

meaningfully involved. Fair treatment is defined as when no group of people 

bears a disproportionate share of negative environmental consequences resulting 

from industrial, governmental, and commercial operations or policies (EPA, 

2010a). Meaningful involvement is defined as when: people have the opportunity 

to participate in decisions about activities that may affect their environment 

and/or health; the public can influence the regulatory agency’s decision; public 

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concerns are considered in the decision making process; and the decision makers 

seek out and facilitate the involvement of potentially affected people. 

Fair treatment and meaningful involvement has been and would continue to be 

implemented by the following: 

	 publishing Notices of Intent and Notices of Availability to announce the 

scoping meeting(s) and document accessibility in the Federal Register 

and/or the local media (e.g., newspaper, radio, television); 

	 consulting with other federal agencies, Tribal leaders, the State and local 

governments, community groups, and similar groups (Section 6.0); 

 developing stakeholder mailing lists; 

 overcoming linguistic, cultural, institutional, and geographic barriers; 

 providing public access to pertinent notices, documents, and meetings; 

 scheduling meetings at convenient times and places that are local and 

accessible; 

 sharing information through different meeting sizes, formats, media, or 

other methods; 

 soliciting feedback and recommendations through written communication, 

personal interviews, audio/video recording devices, or other methods; and 

 periodically updating stakeholders about the NEPA process. 

4.16.4 Environmental Justice Impacts from Other Alternatives 

4.16.4.1 No Action Alternative 

The No Action Alternative would have no environmental justice impacts. 

4.16.4.2 Other Action Alternatives 

Differences in environmental justice impacts are not anticipated between the 

Proposed Action and Other Action Alternatives described in Section 2.0. 

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4.17 Public and Occupational Health 

Potential impacts on public and occupation health are discussed on the basis of 

radiological and non-radiological impacts. 

4.17.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Appendix D10 of the WDEQ-LQD Permit to Mine (LCI, 2011b), Sections 3.12.1, 

3.12.2, 3.12.3, 4.13.1.1, 4.13.1.2, 4.13.1.3, 4.13.1.4, .4.13.2, and.4.13.3 of the of 

the NRC SEIS (NRC, 2011a), and Conditions 9.7, 10.4, 10.14, 10.15, 10.16, 

10.17, 11.6, 12.2, 12.3, 12.5, 12.10, 12.11, and 12.14 of the NRC License (NRC, 

2011b). 

Efficient ISR operation, including mine unit balancing and monitoring, and up-todate techniques for ore processing and for waste storage, handling, and disposal, 

would be used to keep contaminants of concern out of any pathways that could 

result in impacts to public or occupational health. Employee training for both 

routine procedures and for unseen circumstances would help reduce the potential 

for accidents. There are requirements for personnel training, specifying the chain 

of command, equipment calibration, record keeping, and reporting to both the 

agencies and workers. Because of the relatively remote location of the Project, 

mitigation of impacts to the public comes from primarily ensuring visitors to the 

site receive the appropriate training and monitoring, and are only allowed access 

to areas outside of the established exclusion zones. 

4.17.1.1 Protection Measures for Radiological Impacts 

As previously discussed, radiological impacts from the Project are minimal. Mine 

unit and Plant design are intended to result in effective and efficient mining and 

ore processing. For example, the water balance details, the mine unit 

instrumentation, and the Plant design are described in Sections OP 3.6.3.1, OP 

3.6.1.1, and OP 4.4 of the WDEQ-LQD Permit to Mine (LCI, 2011b), 

respectively. Worker training and worker and environmental monitoring would 

be conducted throughout the life of the Project, to ensure that the practices and 

procedures developed prior to the Project are properly implemented and effective 

(Section 5.0 of the NRC Technical Report [LCI, 2010]). In addition to the 

practices and procedures developed before the Project is started, periodic 

reporting to and inspections by the NRC are also required throughout the life of 

the Project. 

As discussed in Section 6.0 of the NRC Technical Report (LCI, 2010), the NRC 

also requires licensed facilities to submit a decommissioning plan for review prior 

to the reclamation of each Mine Unit and prior to Final Reclamation. The plan 

would include details of how a radiation safety program, compliant with 10 CFR 

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Part 20, would be implemented during decommissioning to ensure the safety of 

workers and the public is maintained and applicable safety regulations are 

followed. The existing reclamation plan in the NRC Technical Report specifies 

the necessary surveys prior to reclamation to double check that no unanticipated, 

elevated radiation levels exist in the area to be reclaimed. The plan also specifies 

the radiation levels for determining whether decontaminated equipment must be 

disposed of in a licensed facility or can be reused. 

4.17.1.2 Protection Measures for Non-Radiological Impacts 

Similar to the protection measures of radiological impacts, measures used for nonradiological impacts depend on proper facility design, operation, and maintenance 

and on worker training and worker and environmental monitoring. The Wyoming 

Department of Employment (State OSHA Program) requirements and regulations 

will be followed. In addition to general practices and procedures, specific 

requirements for unique situations are also required. For example, protection 

practices related to facility design and handling and storage of the chemicals that 

would be used at the Project are detailed in Sections 7.5 and 7.6 of the NRC 

Technical Report (LCI, 2010). 

4.17.2 Monitoring of Public and Occupational Health Impacts 

4.17.2.1 Radiological Impacts 

The radiological monitoring required by the NRC is detailed and extensive. 

LCI’s radiological monitoring program is included in Section 5.0 of the NRC 

Technical Report (LCI, 2010). In addition to specifying monitoring locations, 

parameters, and frequency, there are requirements for personnel training, 

specifying the chain of command, equipment calibration, record keeping, and 

reporting to both the agencies and workers. 

The required monitoring addresses both workers and the public. With respect to 

workers, monitoring of the workers, the work place, and the environment is 

required. For example, monitoring of the workers includes radiation badges and, 

for specific work circumstances, may also include breathing zone sampling. 

Examples of work place monitoring include gamma surveys of the ion exchange 

tanks and smear samples of work surfaces. Examples of environmental 

monitoring include routine soil sampling and air particulate sampling at specific 

locations relative to the Plant and Permit Area. 

With respect to the public, the radiological monitoring required by NRC specifies 

monitoring procedures for contractors and visitors to the Project, in addition to 

establishment of exclusion zones where only specified, trained LCI personnel are 

allowed. At the Permit Area boundary, monitoring for radon, gamma, and air 

particulates is required. 

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4.17.2.2 Non-Radiological Impacts 

The monitoring requirements for the non-radiological health impacts of the 

Project are those typical for industries, such as drilling, which are regulated by 

OSHA. In particular, reporting of all accidents, investigating the circumstances 

causing the accident, and implementing improved practices where necessary are 

essential to monitoring the effectiveness of the Project’s health and safety 

practices. The regular inspections of work areas, as described in Section 2.9 of 

the WDEQ-LQD Permit to Mine (LCI, 2011b) and Section 5.0 of the NRC 

Technical Report (LCI, 2010), would also help ensure the Project’s health and 

safety practices are effective. 

4.17.3	 Impact Significance Criteria 

Radiological impacts were evaluated on the basis of potential exposures to 

workers and the public during the Project phases compared to naturally occurring 

and anthropogenic exposures. Both worker and public radiological exposures are 

addressed in NRC regulations in 10 CFR Part 20, which requires licensees to 

implement an NRC-approved radiation monitoring and protection program. 

The non-radiological impacts were evaluated on the basis of relative hazards of 

the work processes (e.g., drilling) and materials (e.g., chemicals). Although the 

Project is a mining operation, the industrial safety aspects associated with the 

Project are regulated by the Wyoming Department of Employment (State OSHA 

Program) because most of the Project activities are more similar to other 

industries (e.g., drilling and manufacturing) than traditional mining. 

4.17.4	 Public and Occupational Health Impacts from the 

Proposed Action 

The Project would use ISR technology to extract uranium from permeable, 

uranium-bearing sandstones. Once extracted, the uranium would be recovered by 

means of ion exchange, elution, and precipitation/filtration to ultimately produce 

yellowcake slurry. The operation plan for the Proposed Action is presented in 

Section 2.0. 

There are no permanent residents within 15 miles of the Permit Area, significantly 

reducing the possibility of public impacts. Potential public health impacts, 

however, were evaluated to ensure the health of occasional near/on-site members 

of the public, such as hunters and ranchers. In addition, the workforce for the ISR 

operation would be relatively small, especially as compared to the work force 

needed for surface mining of uranium and conventional mill operation, reducing 

the possibility of occupational impacts. 

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4.17.4.1 Radiological Impacts 

The purpose of this section is to evaluate the potential impacts for radiological 

exposures above the levels of naturally occurring exposures. Naturally occurring 

exposures are due to the presence of radioactive materials in the earth. (For 

example, radon-222 is a radioactive gas that escapes into ambient air from the 

decay of uranium found in most soils and rocks.) As a result, radioactive 

materials are also found in drinking water and foods. Cosmic radiation from outer 

space is another natural source of radiation. There are also anthropogenic 

sources, such as medical diagnostic procedures using radioisotopes. The National 

Council for Radiation Protection (NCRP) estimates the annual average dose to the 

public from all natural background radiation sources (terrestrial and cosmic) is 

310 millirems (mrem), and the annual average dose to the public from all sources 

(natural and anthropogenic) is 620 mrem (NCRP, 1987). 

Construction 

None of the activities during Construction involve worker exposure to uranium 

ore and associated radiological parameters, with the possible exceptions of shortterm exposure drilling of the deep wells and potential movement of soil with 

elevated radionuclide concentrations. With respect to the deep wells, the 

locations were selected on the basis of minimizing interference with production of 

known uranium resources. Therefore, interception of uranium ore during drilling, 

and subsequent movement of the material to the surface via the drilling process, is 

unlikely. With respect to movement of soil with elevated uranium concentrations, 

the results of the site-wide gamma scan and soil sampling (Section 3.15) do not 

indicate the presence of radionuclides in excessive quantities in Construction 

areas at the surface due to the presence of ore (e.g., an outcrop) or prior 

exploration activities. Practices to prevent worker exposure to inhalation of 

fugitive dust, e.g., dust masks, and to minimize creation and transport of dust, 

e.g., application of magnesium chloride (Section 4.11), that are implemented for 

air quality concerns would reduce the potential for transport of radionuclides in 

soil if they were encountered. 

Exclusion of the public from Construction zones, following standard health and 

safety regulations and practices, along with practices to minimize creation and 

transport of dust, would preclude radionuclide exposure to the public during 

Construction. 

During Mine Unit Development, the drilling of wells in the pattern areas increases 

the potential for exposure to radionuclides as the water and drill cuttings from the 

ore zone are brought to the surface and circulated through the mud pit. However, 

the relative volume of the water and cuttings from the ore zone, which is on the 

order of a few feet thick, relative to the overall volume of drill cuttings from a 

given well, which is several hundred feet deep, is minimal. 

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Section 4.13.1.1 of NRC SEIS discusses that workers would most likely be 

exposed during well construction, disturbing surface soils, and fugitive dust, but 

that concentrations would be low, and any health impacts for employees and the 

general public would be low (NRC, 2011a). 

Operation 

During the Operation phase, radon would be released from the solutions at the 

mine units and vented from the Plant building to the atmosphere during routine 

operation or when vessels are opened for maintenance. Experience from other 

ISR projects shows that these releases would only be a small fraction of the 

natural background dose contribution and would not result in a significant off-site 

impact. Potential public exposures to radiation could occur from the same radon 

releases. The MILDOS-AREA computer code (ANL, 1998) was used to estimate 

potential exposures and doses to human receptors and populations surrounding the 

Permit Area, and the results are summarized below. Details on input parameters, 

exposure pathways, as well as the results of the MILDOS modeling are presented 

in the NRC Technical Report (LCI, 2010). The potential for exposures due to 

accidental releases during the Operation phase was also evaluated as part of the 

Technical Report, and the results are also summarized below. 

Section 4.13.1.2 of the NRC SEIS summarizes how employees and the public can 

become exposed during normal operations and accidents. The expected doses 

during normal operations are below the regulated limits, and any impacts from 

this exposure would not be expected. Additionally, the mitigation efforts to 

prevent accidents and the response plans if an accident does occur minimize the 

threat from spills and reduce the potential impact (NRC, 2011a). 

Operational MILDOS Modeling Results 

Since there are no permanent residents in the vicinity of the Permit Area, radon 

doses were modeled at 17 locations around the perimeter of the Permit Area 

boundary (Figure 4.17-1). The map shows modeled receptor locations, as well as 

centroids of each mine unit. MILDOS calculations and output use metric units; 

this discussion refers to English and metric length units for the sake of 

consistency. 

MILDOS modeling indicates that releases from the site lead to a maximum 

calculated total effective dose equivalent (TEDE) to a potential resident at the 

SEB1 boundary location of 3.01 mrem, which is well below the 100-mrem-peryear limit of Title 10 CFR Part 20 (Figure 4.17-2). No other boundary location 

exceeds 2 mrem in a given year and most are below 1 mrem. The vast majority of 

the calculated doses at the SEB1 location are from venting during operation, 

which occurs at the centroid of the mine unit. Most mine units are upwind of the 

SEB1 location. 

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There are no towns of any size within 15 miles of the Permit Area. While there 

are no standards for population dose, it is interesting to compare population doses 

from the Project, calculated from MILDOS, to the natural background for the 

same region. The average US resident receives 360 mrem per year (NRCP, 

1987). When applying this average US effective dose to the MILDOS population 

(8,985 residents), the natural background population dose (TEDE) would be 

approximately 3,200 person-rem per year, which is over 170,000 times higher 

than that of the calculated maximum 0.019 person-rem-per-year population dose 

within 50 miles of the Permit Area. 

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Figure 4.17-2 TEDE at Boundary Receptor Points 

TEDE by Receptor by Year

0.00E+00

5.00E-01

1.00E+00

1.50E+00

2.00E+00

2.50E+00

3.00E+00

3.50E+00

2009 2010 2011 2012 2013 2014 2015 2016 2017 mrem

NB NEB EB1 SB SWB4 WB 

NWB EB2 EB3 SEB1 SEB2 SEB3 

SWB3 SWB2 SWB1 SEB4 SEB5

MILDOS is not commonly used to calculate occupational doses, because such 

doses are calculated using results of personnel monitoring during facility 

operation. However, a hypothetical worker location was used in MILDOS to 

calculate doses through the operation of the Plant. The worker location was 

modeled once for 328 feet (100 meters) to the north, east, south and west of the 

ion exchange facility. For each worker receptor location, a dose was calculated, 

multiplied by 0.22 to represent an occupational year (2,000 work hours in an 

8,760-hour year), and averaged. The maximum worker dose would be 0.3 mrem 

in 2014, which is well below the occupational standard of five rem (Figure 

4.17-3). This value is likely an overestimate for a worker at the specified 

locations, because MILDOS includes contributions from pathways, such as 

ingestion of vegetation, which would not apply to the Permit Area. During 

operation of the facility, workers at the site would be monitored and occupational 

doses calculated in accordance with the NRC License. 

There are no current dosimetric standards for protection of biota. However, it has 

been assumed by the International Commission on Radiological Protection that if 

humans were protected, then biota in the same exposure environment would also 

be protected. 

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Figure 4.17-3 MILDOS-Calculated Doses to a Hypothetical Worker 

328 feet (100 meters) from the Plant, Averaged over 

Direction 

Accidental Releases 

The precautions put into place for the Project are intended to reduce the risk of 

accidents and associated releases as much as possible. Even so, the consequences 

of various on-site accidents and transportation accidents were evaluated as part of 

the NRC Technical Report (LCI, 2010). Specifically, Sections 4.1.2, 7.4.1, and 

7.4.2 include evaluations of the consequences of releases from areas in the Plant 

with the higher concentrations of radioactive material, such as the yellowcake 

slurry storage tanks. Similarly, Section 7.2.7 includes evaluations of the 

consequences of off-site transportation accidents. 

Reclamation 

Exposures to workers could occur during disassembly of equipment used to 

convey production fluids from the mine units and equipment used in the Plant. 

Decontamination of equipment could also result in exposures, and for equipment 

that cannot be decontaminated, packaging of the equipment for transport to a 

designated disposal facility could also result in exposure if not done in accordance 

with specified practices and procedures. 

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Sections 4.13.1.3 and 4.13.1.4 of the NRC SEIS discuss that while there is a 

potential for some exposure during the reclamation efforts, the mitigation efforts 

and the clean-up of the area reduces these, and the impact on public and worker 

health is expected to be minimal (NRC, 2011a). 

4.17.4.2 Non-Radiological Impacts 

Increased traffic from the Project would increase the amount of gaseous emissions 

and airborne particulates. Potential impacts from these emissions are discussed in 

Section 4.11. 

Construction 

During Construction, most of the potential non-radiological impacts are related to 

mechanical hazards, such as operation of heavy equipment and drilling, and to 

exposure of emissions from engines on vehicles and equipment. Potential impacts 

include injuries or irritation of the eyes, nose, or respiratory system. 

Section 4.13.1.1 or the NRC SEIS discusses the potential exposure to emissions 

from diesel exhaust fumes, but explains that the short exposure time and the quick 

dispersal into the atmosphere lead to minimal impacts (NRC, 2011a). 

Operation 

During the Operation phase, there are potential chemical exposures. Chemicals 

used in bulk quantities at the Permit Area would include sodium chloride, sulfuric 

acid, oxygen, hydrogen peroxide, CO2, sodium carbonate, hydrochloric acid, as 

wells as fuels (diesel and gasoline), and smaller quantities of chemicals may be 

needed for laboratory procedures. As with radioactive materials, the precautions 

put into place for the Project are intended to reduce the risk of accidents and 

associated releases as much as possible. Even so, the consequences of various onsite accidents and transportation accidents were evaluated as part of the NRC 

Technical Report (LCI, 2010). Specifically, Sections 7.5 and 7.6 include 

evaluations of the consequences of releases from areas in the Plant in which 

chemicals would be stored and used, such as the hydrochloric acid storage tanks. 

Similarly, Section 7.4.7 includes evaluations of the consequences of off-site 

transportation accidents. 

Section 4.13.1.2.3 of the NRC SEIS discusses the potential impacts from working 

with the chemicals present on-site. Any spills would have a minimal impact on 

the public off-site, but a potentially higher impact on workers if proper clean-up is 

not accomplished shortly after the spill. However, with the spill prevention and 

mitigation measures the impact from these spills is reduced since if one occurs, it 

would be properly addressed (NRC, 2011a). 

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Reclamation 

The primary concerns during Reclamation would be similar to those during 

Construction, including operation of heavy equipment and exposure to engine 

emissions. 

Section 4.13.1.4 of the NRC SEIS discusses the potential health impacts that 

could occur during Reclamation. The NRC suggests that as cleaning efforts 

progress in the Permit area, the likelihood for health impacts decreases, and that 

overall, the impact would be minimal (NRC, 2011a). 

4.17.5	 Public and Occupational Health Impacts from Other 

Alternatives 

4.17.5.1 No Action Alternative 

The No Action Alternative would generate no impact on public and occupational 

health. 

4.17.5.2 Other Action Alternatives 

The alternative of Not Fencing the Pattern Areas increases the potential for access 

to the pattern areas. The primary concern is that cattle or wild horses would 

damage the well heads, resulting in a release of production fluid, i.e., a 

radiological exposure. Procedures that are in place for detecting releases, 

repairing equipment, and implementing appropriate remediation measures would 

reduce the potential for exposure to radiological materials. With respect to nonradiological hazards, fencing the pattern areas reduces the potential access for 

someone unfamiliar with the pattern area hazards (e.g., trip and fall hazards in the 

header houses). 

The alternative for Drying Yellowcake On-Site increases the potential radiation 

exposure to workers in the Plant. The potential exposure is not during operation 

of the dryer, because the vacuum system is designed to prevent release of 

radiological particulates. The potential exposure could occur during maintenance 

and reclamation of the dryer or during an accidental release, and this exposure 

would be similar to that of the Proposed Action. In addition, before a dryer could 

be installed, an NRC license amendment would be required, which would include 

further detail on dryer operation, monitoring, and decommissioning. The vacuum 

dryer and associated equipment would not be significantly more complex than the 

other processing equipment in the Plant; therefore, the potential increase in nonradiological impacts would be minimal. Because the dryer would be located 

within a restricted area of the Plant, there would be no potential for public 

exposure during routine operations. 

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4.18 Waste Management 

During the Project, gaseous/airborne, liquid, and solid effluents would be 

generated from the processes associated with ISR operations. All of the effluents 

are typical for ISR projects currently operating in Wyoming, and existing 

technologies are amenable to all aspects of effluent control in the Permit Area. 

Waste streams from different phases of the Project and waste management 

practices for the Project are described in Section 2.1. The waste management 

control practices are also described in Section OP 5.0 of the WDEQ-LQD Permit 

to Mine (LCI, 2011b) and Section 4.0 of the NRC Technical Report (LCI, 2010). 

4.18.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Sections OP 5.2, 5.3 and RP 4.2 of the WDEQ-LQD Permit to Mine (LCI, 

2011b), Sections 2.1.1.1.6.2 and 2.1.1.1.6.3 of the NRC SEIS (NRC, 2011a), and 

Conditions 9.6, 9.9, 11.1(D), and 12.6 of the NRC License (NRC, 2011b). 

The monitoring programs for non-radioactive emissions and particulates and for 

radon are described in Sections 4.11 and 4.17, respectively. 

Liquid and solid wastes would be reduced by reusing/recycling materials 

whenever possible. The primary measures that would be employed to mitigate 

waste management impacts would be reduction of wastes and proper storage, 

handling, and disposal of wastes. Similarly, instrumentation and inspection of 

process facilities for timely identification and remediation of leaks and spills 

would reduce the potential for generating large volumes of wastes that would 

need to be disposed of at a licensed facility. In addition, by disposing of solid 

non-hazardous wastes at licensed facilities off-site, solid wastes would not be 

present in the Permit Area after the Project is completed. (For example, at 

conventional open pit mines, building rubble is often disposed of on-site.) The 

exception is that well casings may remain in place; however, the casing must be 

cut off below grade and a deed notice completed to document the well locations 

(WDEQ-LQD NonCoal Rules, Chapter 11, Section 8(h)(i) [WDEQ, 2005b]). 

4.18.2 Monitoring of Waste Disposal Impacts 

Gaseous Emissions and Airborne Particulates 

The monitoring programs for non-radioactive emissions and particulates and for 

radon are described in Sections 4.11 and 4.17, respectively. 

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Liquid and Solid Wastes 

The Storage Ponds and UIC Class I wells would be routinely inspected, 

maintained and tested to ensure that any impact-generating potential is kept to 

minimum. The septic system would be maintained in accordance with the 

Sweetwater County permit. The UIC Class I wells would be monitored in 

accordance with the requirements of the UIC permit. An evaluation of the well 

performance would be included in the Annual Report submitted to NRC and 

WDEQ. 

Monitoring of solid wastes would include inspection to ensure proper storage, 

selection of licensed disposal contractors, and periodic audits of labels, manifests, 

and disposal practices. 

4.18.3 Impact Significance Criteria 

The criteria used to evaluate the impacts of waste management activities are the 

availability of appropriate treatment options and disposal facilities, the capacity of 

those disposal facilities (e.g., whether the volume of Project wastes would overtax 

the facilities), and efficiency of the disposal option (e.g., disposal versus reuse). 

The impacts of the waste management facilities on specific resources are 

evaluated in the respective resource sections (e.g., the impacts of the Storage 

Ponds on wildlife are discussed in the Section 4.9). 

Section 4.14 of the NRC SEIS addresses waste management impacts. Wastes 

identified include liquid waste, both radiological and non-radiological, and solid 

wastes. However, due to the contents, quantity, and management measures, the 

impact from waste is expected to be small (NRC, 2011a). 

4.18.4 Waste Disposal Impacts from the Proposed Action 

The following discussion is separated on the basis of the type of effluent, i.e., 

gaseous/airborne, liquid, or solid effluent, and then on the basis of the phase of 

the Project, i.e., Construction, Operation, and Reclamation. 

4.18.4.1 Gaseous Emissions and Airborne Particulates 

As described in Section 2.1, non-radioactive and radioactive airborne effluents 

are anticipated during the Project; however, the relative quantities vary among the 

Construction, Operation, and Reclamation phases of the Project. 

Non-Radioactive Emissions and Particulates 

Most non-radioactive emissions and particulates would be generated during 

Construction, when the most earth moving would occur and heavy machinery 

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would be used for building the Plant. The impacts are, however, short-term. 

Compared with the Construction phase, fewer amounts of non-radioactive 

effluents are expected during the Operation phase and, thus, less impact is 

anticipated. Impacts during the Reclamation phase are short-term; and the 

amount of emission and particulates generated would be less than those from 

Mine Unit Development but more than those from Operation. Detailed 

discussions of non-radioactive emissions and particulates generated during the 

Project, as well as their potential impacts, are presented in Section 4.11. 

Radioactive Emissions 

Almost all of the expected radioactive emissions would occur during the 

Operation phase. There would be minimal radioactive emission, if any, during 

Construction, and limited amount during Reclamation. Radon would be the 

radioactive gaseous emission from ISR production and processing, as it is 

naturally present in the orebody and concentrated in the lixiviant solution. Radon 

would be released occasionally from the mine unit wells as gas is vented from the 

injection and production wells. Radon would also be released during ion 

exchange resin transfers and subsequent processing steps, as described in more 

detail below. Detailed discussions of radioactive emissions generated during the 

Project, as well as their potential impacts, are presented in Section 4.17. 

4.18.4.2 Liquid Wastes 

Most of the liquid wastes (in terms of both type and amount [Table 2.1-1]) would 

be generated during Operation. Table 4.18-1 summarizes the types of liquid 

wastes generated during the Project phases. 

Table 4.18-1 Summary of Liquid Wastes Generated during 

Different Phases of the Project
 

Liquid Waste Construction Operation Reclamation 

Native Groundwater Yes Yes No 

Storm Water Runoff Yes Yes Yes 

Waste Petroleum Products and 

Chemicals Yes Yes Yes 

Domestic Sewage Yes Yes Yes 

11(e)(2) Byproduct Materials No Yes Yes 

“Native” Groundwater Recovered during Well Development, Sample 

Collection, and Pump Testing 

In Construction, groundwater is recovered during well installation, sample 

collection, and pump testing conducted prior to Operation or from portions of the 

Permit Area not affected by ISR operations. This “native” groundwater has not 

been exposed to any ISR process or chemicals. During well development, sample 

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collection, and pump testing, this water would be discharged to the surface under 

the provisions of a general WYPDES permit, in a manner that mitigates erosion, 

or reused in the drilling process. Because of the relatively small quantities of 

water discharged at any given time, no impacts are anticipated. 

Storm Water Runoff 

Throughout the Project, the storm water discharge permits applicable per the 

WYPDES would be maintained. The associated SWPPP would be implemented 

as part of LCI’s compliance with applicable WDEQ-WQD rules. A copy of the 

SWPPP is included as Attachment ADJ-3 of the WDEQ-LQD Permit to Mine 

(LCI, 2011b), and a copy would be in an accessible area at the site. /Because of 

the limited precipitation at the Permit Area, no impacts are anticipated. 

Waste Petroleum Products and Chemicals 

LCI would generate about 40 to 80 gallons of waste petroleum products per 

month, which would be periodically collected by a commercial business for 

recycling or energy recovery purposes. With respect to hazardous wastes, LCI 

would be a Conditionally Exempt Small Quantity Generator (CESQG), per EPA 

definition. About five to ten gallons of waste chemicals not immediately 

associated with laboratory operations would be generated per year. These waste 

chemicals would be periodically collected by a commercial business for recycling 

or disposal in a licensed disposal facility. As a CESQG, LCI could send the 

hazardous waste to the Sweetwater County District #1 Landfill in Rock Springs 

(Section 4.18.4.3). However, if recycling or reuse alternatives are available, 

those alternatives would be used to reduce the potential waste disposal impact. 

Waste chemicals typically associated with the laboratory operations would be 

captured in the drains and/or sumps within the laboratory and would go straight to 

Plant waste tanks for eventual deep well disposal. An estimated five to ten 

gallons of these waste chemicals would be disposed of per year. The impacts of 

the UIC Class I wells are discussed in Section 4.7. 

Domestic Sewage 

Domestic liquid waste would be disposed of in an approved septic system that 

meets the requirements of the WDEQ-WQD. A permit would be obtained for the 

septic system prior to construction of the system. The septic system would receive 

waste from the restrooms, shower facilities, and miscellaneous sinks located 

within the office. The septic system, which is also permitted by Sweetwater 

County, would be maintained by a licensed contractor. Given the lack of shallow 

groundwater at the site, the remote location, and the relatively small work force, 

impacts to the Permit Area would be limited. 

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In addition, chemical toilets may be temporarily placed at mine units and other 

drilling areas. The chemical toilets would be maintained by a licensed contractor, 

and no impacts are anticipated in the Permit Area. 

Liquid 11(e)(2) Byproduct Materials 

The three 11(e)(2) byproduct materials (liquid process wastes, ‘affected’ 

groundwater generated during well development, and groundwater generated 

during aquifer restoration) would be treated and disposed of on-site through the 

Storage Ponds and UIC Class I wells. Because of the controlled on-site disposal 

procedures, no impacts from the liquid process wastes, other than those associated 

with the UIC Class I wells, are anticipated in the Permit Area. The Storage Pond 

impacts and the UIC Class I well impacts are discussed in Section 4.7. 

The WDEQ has issued a permit to the applicant to drill, operate, and complete the 

UIC Class I wells in specific geologic formations. The permit specifies well 

construction, testing and operating conditions the applicant must follow to ensure 

adequate protection of the public and environmental health and safety. The 

permitted disposal rate is 250 gpm, based on a 50 gpm rate for each well. The 

maximum anticipated disposal rate based on the water balance for the Project is 

115 gpm. Therefore, even allowing for redundancy, there is sufficient disposal 

capacity for the Project. 

4.18.4.3 Solid Wastes 

Table 4.18-2 summarizes the solid wastes generated during the Project phases. 

Most solid wastes generated during Construction would be non-hazardous (Table 

2.1-1); no 11(e)(2) byproduct materials would be produced during Construction. 

Table 4.18-2 Summary of Solid Wastes Generated during Different 

Phases of the Project 

Solid Waste Construction Operation Reclamation 

Non-Hazardous Wastes Yes Yes Yes 

Hazardous Wastes Yes Yes Yes 

11(e)(2) Byproduct Materials No Yes Yes 

Non-Hazardous Solid Wastes 

During Construction, most solid wastes would be typical construction debris, 

including scrap metal, paper, wood, and plastic. Based on empirical assessments 

of non-residential construction debris (Franklin Associates, 1998), an estimated 

average weight to volume conversion rate of 100 for such debris (California 

Department of Resources Recycling and Recovery, 2001), and a construction area 

of 100,000 square feet, about 150 cubic yards of construction debris would be 

generated. (The Plant covers about 41,600 square feet, but because of the variety 

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of facilities, such as the Storage Ponds, a larger square footage was assumed.) 

During Operation, about 55 cubic yards of non-hazardous solid wastes would be 

generated each year (LCI, 2011b). During Reclamation, an estimated 1,400 cubic 

yards of non-hazardous materials would be generated (NRC, 2011a). 

The non-hazardous materials would be recycled when possible or temporarily 

stored in commercial bins prior to disposal by a contracted waste disposal 

operator at a licensed waste disposal facility. As noted in the NRC SEIS, “The 

closest location for disposal of non-hazardous solid wastes is the Carbon County 

landfill north of Rawlins, Wyoming”...“The municipal waste and the construction 

and demolition waste cells at the Carbon County landfill are not at or near 

capacity” (NRC, 2011a). The Rawlins Landfill has an anticipated life expectancy 

of 50 years, based on its current rates of waste disposal. The landfill does not 

accept liquid, industrial, or hazardous wastes. All wastes received at the landfill 

are disposed there, and no wastes are transferred to other facilities. 

Hazardous Solid Wastes 

Hazardous wastes, such as solvents, paints, used oil, batteries, and fluorescent 

bulbs, would be a significantly smaller percentage of the solid wastes generated 

during the Project than non-hazardous wastes. The closest location for disposal of 

hazardous solid wastes is the Rock Springs Landfill. As noted in the NRC SEIS, 

the facility has the capacity and is also in the process of permitting additional 

capacity that would expand the life of the landfill about 30 years (NRC, 2011a). 

Solid 11(e)(2) Byproduct Materials 

Solid 11(e)(2) byproduct materials would include process wastes, such as spent 

ion exchange resin, filter media, and tank sludge, generated during ISR and ore 

processing, and would include equipment that becomes contaminated during ISR 

and ore processing. These items include tanks, vessels, PPE, and process pipe 

and equipment. Such wastes could also include soils contaminated from spills. 

No solid 11(e)(2) byproduct materials would be generated during Construction. 

Approximately 80 to 100 cubic yards of solid 11(e)(2) by-product materials 

would be generated each year during Operation (LCI, 2011b), including 

maintenance and housekeeping items, such as cleaning equipment, replacement 

components, filters, protective clothing, solids removed from process pumps and 

vessels, and any soils or other materials that cannot be decontaminated. The 

annual amounts would be somewhat higher during reclamation of the mine units 

as the equipment from the mine units is taken out of service. The total estimated 

amount of 11(e)(2) byproduct material from the Project, including Reclamation, is 

estimated to be 4,000 cubic yards (NRC, 2011a). 

Where possible, equipment would be decontaminated for disposal as non-11(e)(2) 

byproduct material or for reuse. Equipment that cannot be decontaminated and 

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process wastes would be placed in clearly labeled, covered containers and 

temporarily stored in restricted areas with clearly visible radioactive warning 

signs. The materials would be temporarily stored on-site in containers called 

‘super-sacs’. Sacs that are full would be sealed and stored in secure areas in the 

Plant or outdoors in strong, tight, covered roll-off containers approved by the US 

DOT for transport of Low Specific Activity material until sufficient volume is 

generated for shipment to a facility that is licensed for treatment and/or disposal. 

Safe handling, storage, and disposal of decommissioning wastes are addressed in 

Sections 4.0 through 6.0 of the NRC Technical Report (LCI, 2010), and these 

procedures would be reviewed and updated, if necessary, in the decommissioning 

plan which must be submitted to NRC for review and approval prior to initiation 

of decommissioning activities. Because of the controlled off-site disposal 

procedures, no impacts from the non-hazardous solid waste disposal are 

anticipated in the Permit Area. 

The solid 11(e)(2) byproduct materials would be disposed off-site, at a facility 

licensed by the NRC to accept such wastes, by personnel qualified to dispose of 

such wastes. At present, LCI does not have an agreement with such a facility; 

however, prior to the start of operations, LCI would enter into a written agreement 

with a disposal site as required by the NRC. A licensed facility may be a uranium 

mill tailings impoundment, and the closest would be the Pathfinder Shirley Basin 

Facility in Wyoming. Other NRC-licensed facilities that can accept byproduct 

material for disposal include: the Rio Algom Ambrosia Lake facility near Grants, 

New Mexico; the Energy Solutions site in Clive, Utah; the White Mesa facility in 

Blanding, Utah; and the Waste Controls Specialists site in Andrews, Texas. 

4.18.5 Waste Disposal Impacts from Other Alternatives 

The No Action Alternative would not generate any of the ISR wastes and thus no 

impacts would be created. With respect to waste management, there are no 

significant differences in the anticipated impacts, or in the monitoring and 

mitigation, between the Proposed Action and the Other Action Alternatives 

described in Section 2.0. Slightly less solid waste, specifically fencing materials, 

would be generated if the pattern areas were not fenced. However, the difference 

in volume of solid waste, if the fencing material was disposed of rather than 

reused, is minimal compared to the overall Project. 

Processing wet yellowcake into a dry powder is not expected to change the nature 

or magnitude of waste disposal impacts as a vacuum dryer would be used. In a 

vacuum dryer, the heating system is isolated from the yellowcake so no 

radioactive materials are entrained in the heating system or its exhaust. The 

drying train would operate under a negative pressure to avoid atmospheric 

emissions, and drying would take place at relatively low temperatures. Emissions 

from the drying chamber would be normally treated through a bag filter to remove 

yellowcake particulates, and air from the bag filter dust collection system would 

typically be routed to the dryer offgas line and scrubber. A small volume of 

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liquid effluent from the vacuum dryer would be cooled and condensed for 

disposal as 11(e)(2) byproduct material in the UIC Class I wells; however, the 

volume would be minimal compared to the total volume of material from the 

Project. During loading of the dried yellowcake into a drum, the typical shipping 

container, the drum would also be kept under negative pressure via a drum hood 

with a suction line. The packaging area also has a bag filter dust collection 

system to protect personnel and to minimize yellowcake release. The vacuum 

drying equipment would need to be decommissioned in accordance with NRC 

requirements. Filters and dryer equipment that could not be decommissioned 

would be disposed of as solid 11(e)(2) byproduct material; however, the volume 

would be minimal compared to the total volume of material from the Project. 

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4.19	 Mitigation Measures 

Mitigation includes specific means, measures, or practices that would reduce or 

eliminate effects of the Proposed Action or alternatives. The agency-required 

measures, LCI’s commitments and initiatives, and monitoring presented in the 

previous subsections of Section 4.0 would provide adequate protection of 

resources and mitigation of impacts from the Proposed Action and alternatives. 

No additional mitigation measures are identified. 

4.20 Residual Impacts 

Residual impacts are adverse effects that remain after mitigation measures have 

been applied. Since the agency-required measures, LCI’s commitments and 

initiatives, and monitoring presented in the previous subsections of Section 4.0 

would provide adequate protection of resources and mitigation of impacts from 

the Proposed Action and alternatives, no additional mitigation measures were 

proposed in Section 4.19 (Mitigation Measures). Since no additional mitigation 

measures have been proposed, no residual impacts discussion is required. All 

impacts would remain as previously described in the subsections of Section 4.0. 

4.21	 Irreversible and Irretrievable Commitments of 

Resources 

Irreversible commitments of resources are actions that disturb or remove a 

resource to the point that it can only be renewed over a long period of time 

(centuries). A resource is irreversibly committed when it cannot be restored or 

returned to its original or pre-disturbance condition and when it, its productivity 

or its utility would be consumed, committed, or lost forever. 

An irretrievable commitment of a resource directly removes the resource from 

availability or renders its productivity or utility lost for a period of time (e.g., 

closure of an area to resource extraction). An irretrievable commitment is the loss 

of opportunities for production or use of a renewable resource for a short to 

medium period of time (years). A resource is irretrievably committed when a 

decision results in the loss of production or future use of the resource. 

The removal of uranium from the subsurface would be an irreversible and 

irretrievable commitment of resources. While the uranium is irreversibly 

removed from the ground, it is also irretrievably committed to present-day uses 

rather than potential uses at some undetermined future time. Other irretrievably 

committed resources of the Proposed Action and alternatives include building 

materials, electricity, fuels, office supplies, and other products consumed during 

the Project. 

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While surface disturbing and disruptive activities of the Proposed Action and 

alternatives are considered an irretrievable commitment of resources during the 

Project life, the environmental protection measures required for the Proposed 

Action and alternatives would reduce or eliminate the magnitude of this 

irretrievable commitment of resources. In the long-term, however, the resource 

commitment of surface disturbing and disruptive activities would be retrievable. 

4.22	 Relationship between Short-Term Uses and LongTerm Productivity 

The Proposed Action and alternatives would result in the potential for loss in 

long-term productivity; however, the required environmental protection measures 

for the Proposed Action and alternatives would minimize the effect of short-term 

uses on long-term productivity. 

The extracted uranium would support present-day objectives and not contribute to 

the national long-term productivity or production and use of uranium. Currently, 

the national nuclear energy industry (including domestic uranium production) is 

expanding to meet increasing energy demands, increased interest in energy 

security, and increased demand for alternative energy sources. At present, the US 

is importing most of the uranium used to fuel existing nuclear reactors in the 

country. Recent national programs, statutes, and initiatives include: 

 the Nuclear Power 2010 program of the US Department of Energy; 

 the Energy Policy Act of 2005; 

 the American Recovery and Reinvestment Act of 2009; 

 the Nuclear Energy Research Initiative; 

 Nuclear Energy University Programs; and 

 Generation IV Nuclear Energy Systems. 

The State of Wyoming is historically, culturally, and economically tied to the 

mining industry. With its long-standing mining background and the largest 

uranium reserves in the US, Wyoming is well-equipped to play a leading role in 

the nation’s uranium production. Uranium mining in Wyoming would not only 

help to diversify the nation’s energy sources, it would offset the boom and bust 

cycles of other Wyoming natural resource development industries through 

diversification. 

The short-term extraction of uranium would limit the long-term productivity of 

mineral resource extraction in the Permit Area at some point in the future. The 

uranium mineral resource remaining after the Proposed Action would be minimal 

since the Proposed Action anticipates at least an 80-percent recovery rate of the 

resource. However, other mineral resources could be discovered in economic 

quantities and recovered within the Permit Area in the future. 

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Present-day removal of uranium may indirectly improve long-term productivity 

by reducing the radioactivity of material associated with extracted uranium, 

thereby benefitting the health of humans and the environment by minimizing 

potential exposure. 

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