2.0 PROPOSED ACTION AND ALTERNATIVES

2.1.8 Prevention, Reporting, and Correction of Accidental 

Releases 

LCI would be required to conduct activities in a manner that minimizes the risk of 

accidents and provides for prompt reporting and remediation of releases, as 

required per the licenses and permits from agencies, including the NRC, the 

WDEQ-LQD, and the WDEQ-WQD. The requirements from the various licenses 

and permits are summarized in this section. 

2.1.8.1 Prevention 

As discussed in the Operations Plan of the WDEQ-LQD Permit to Mine (LCI, 

2011b) and the NRC Technical Report (LCI, 2010), LCI would conduct the 

following actions to reduce the potential for accidental releases:

x Appropriate engineering design, construction, and maintenance of 

facilities;

x On-going employee training; 

x Development and implementation of Standard Operating Procedures 

(SOPs) and plans, such as the SWPPP, covering topics including: 

o pipeline installation and testing; 

o automated system monitoring and alarming; 

o site inspections; and 

o corrective actions. 

Table 2.1-3 lists the measures that would be taken to prevent the risk of spill and 

leaks for the various facilities at the Permit Area. A comprehensive training 

program would be developed and implemented prior to the initiation of operations 

to ensure that on-site personnel are familiar with the physical and chemical 

hazards present in the work place and how to successfully mitigate those hazards. 

The training program would include, at a minimum, the following items: 

x The distribution of physical and chemical hazards in the work area and 

throughout the Plant and mine units; 

x Methods and observations that are in place or may be used to detect the 

presence or release of a hazardous chemical in the work area; 

x The measures employees can take to protect themselves from the hazards, 

such as in-place work practices and PPE to be used; 

x Emergency procedures (including evacuation and notification of public

emergency response personnel); 

x Details of the hazard communication program, including the labeling 

system; 

x Material safety data sheets and how employees can obtain and use the 

appropriate hazard information; 

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x Physical hazards presented by process tankage, piping, and equipment and 

how individuals may mitigate these hazards (lockout/tagout, confined 

space, moving parts, cryogenic fluids, and so forth); and 

x The potential for upset conditions and how to safely mitigate these 

conditions. 

LCI would designate an Environmental Health and Safety (EHS) Supervisor who 

would ensure that all individuals that may be exposed to processing hazards 

receive initial training. The EHS Supervisor would also ensure that employees 

and contractors receive the appropriate initial and refresher training. When an 

employee or contractor is given a new task, the supervisor would assess if 

additional training would be needed and provide all necessary training before the 

individual would be exposed to the hazard. On-the-job training would only be 

acceptable if an experienced operator is on-hand to immediately oversee all

activities. All training would be documented by the trainer, with records 

maintained until the associated licenses and permits are terminated. 

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Table 2.1-3 Spill Prevention Measures (Page 1 of 2)

Potential Source of 

Spills or Leaks Prevention Measures

Pipelines, Fittings, 

Valves

x

x

x

x

x

x

x

x

All Plant equipment designed for the life of the 

Project

Pipelines constructed of corrosion-free high-density 

polyethylene (HDPE) material

Pipelines buried 5 to 6 feet below the ground surface

Pipeline junctions made of either corrosion-free 

HDPE material, stainless steel, epoxy-coated steel or 

a combination of the three

Pipeline systems equipped with high and low 

pressure shutdown systems and flow meters

Pipeline systems equipped with alarms to alert the 

operator immediately of malfunctions

Daily visual inspections of pipelines, valve stations, 

power lines, header houses, well heads, fences roads, 

and culverts by mine site staff

Routine inspections by the mine unit operators

Buildings (Tanks, 

Plant, header houses, 

and pump houses)

x

x

Tanks and vessels would be inside the Plant, where 

possible; fuel tanks and other materials which could 

not be stored inside the Plant would have approved 

containment

The Plant would have a concrete containment 

curbing around the perimeter and several internal 

berms and sumps to contain spills
2.0 PROPOSED ACTION AND ALTERNATIVES

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Table 2.1-3 Spill Prevention Measures (Page 2 of 2) 

Potential Source of 

Spills or Leaks Prevention Measures

x Header houses and pump houses equipped with 

sumps to contain spills Sumps equipped with fluiddetection sensors wired to automatic alarms and 

Buildings (Tanks, 

Plant, header houses, 

and pump houses)

Continued 

x

x

x

shutoffs

Alarms and automatic controls to keep fluid levels 

within the prescribed limits

Daily visual inspections of pipelines, valve stations, 

power lines, header houses, well heads, fences roads, 

and culverts by mine site staff

Routine inspections by the mine unit operators

x Two duplicate ponds constructed to allow for the 

complete removal of fluid from one pond to the 

other in the event of a liner leak

Storage Ponds

x

x

x

Storage Ponds equipped with leak detection systems 

between an impermeable base liner and the top liner

Each impermeable liner would be 40 mils thick

Maximum fluid depth of four feet with three feet of 

free board

x Storage Ponds would be kept full of water to 

maintain their integrity by reducing liner exposure to 

the elements

x Storage Pond embankments, fences, liners and free 

board inspected routinely

Wells

x

x

Monitoring of well construction, pressures in the 

ISR system, mine unit balancing, and MITs of wells

Monitoring water levels and water quality in 

adjacent aquifers conducted routinely

Exploration Drill 

Holes

x

x

x

x

Boreholes plugged and abandoned with bentonite

mud or grouted

Monitoring water levels and water quality in 

adjacent aquifers conducted routinely

Pumping tests conducted prior to mine unit start-up 

to ensure no communication between aquifers

If there appears to be communication through 

historic drill holes, those drill holes would be reentered and plugged

Transportation 

x

x

x

x

Regular road maintenance

Driver safety training 

Use of proper containers

Chain of command for emergency response
2.0 PROPOSED ACTION AND ALTERNATIVES

2.1.8.2 Reporting 

Accident situations would require reporting and sometimes emergency 

notification of various agencies. LCI would write and implement an Emergency 

Response SOP that clearly defines under which circumstances reporting is 

required and to which agency(ies). Each spill report would be documented in a 

spill file that would be maintained until the facility is decommissioned and the 

associated licenses and permit are terminated. Each annual report submitted to 

the agencies would contain a map showing the location and date of each 

reportable spill along with a table characterizing the date, volume, area, depth, 

contamination level, sampling locations and remediation efforts for each 

reportable spill. 

2.1.8.3 Corrective Action 

Corrective action would address immediate repairs to stop any releases, clean up 

and remediation of any releases, and assessment and implementation of any 

changes needed in work processes or equipment to prevent a recurrence. If an 

upset condition resulted in the release of mining solutions or chemicals to the 

environment, the affected system(s) would be shut down and thoroughly 

inspected/tested by an individual familiar with that system before being restarted. 

Clean up and remediation actions, including determining the extent of a release, 

the resource(s) impacted, and appropriate actions to remove or remediate any 

contamination would be implemented in accordance with agency requirements. 

2.2 Agency-Required Measures 

Agency-required measures and LCI’s commitments and initiatives to comply with 

the applicable environmental statutory and regulatory programs have developed 

through several federal, state, and local permitting and licensing processes. As 

summarized in Sections 1.4 and 1.5, the Project has completed the permitting and 

licensing processes for the NRC, the WDEQ Land Quality, Water Quality, and 

Air Quality Divisions, and Sweetwater County, among others. The majority of 

these processes has included public notices and comment periods for scoping and 

review of agency approvals and opportunities for hearing in accordance with the 

specific agency requirements. In some instances, no public comments were 

received, and in others, extensive comments were received and addressed. As 

part of the WDEQ-LQD permitting process, an objection to issuance of the Permit 

to Mine was received and a hearing held before the Wyoming EQC. The WDEQLQD decision was upheld (EQC, 2011). 

The BLM reviewed the permitting and licensing actions, in particular the WDEQLQD Permit to Mine (2011b) and the NRC SEIS and License (2011a and 2011b),

and the required environmental protection measures associated with them. Table 

2.2-1 is a cross-reference, by resource and activity, to the sections of the WDEQLQD Permit to Mine, NRC SEIS, and License in which the required 

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environmental protection measures are discussed. The resources and activities 

are: 

x Land Use; 

x Transportation; 

x Geology, Ore Mineralogy and Seismology; 

x Soils; 

x Surface Water, Wetlands and Aquatic Ecology; 

x Groundwater; 

x Vegetation; 

x Wildlife; 

x Wild Horses; 

x Meteorology, Climatology and Air Quality; 

x Noise; 

x Historic and Cultural Resources; 

x Visual and Scenic Resources; 

x Socioeconomic Conditions; 

x Background Radiology; 

x Public and Occupational Health; 

x Waste Management; and 

x Financial Surety. 

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Table 2.2-1 Cross-References to Environmental Protection 

Measures and Impacts in WDEQ-LQD and NRC Documents 

(Page 1 of 5) 
2.0 PROPOSED ACTION AND ALTERNATIVES

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Table 2.2-1 Cross-References to Environmental Protection 

Measures and Impacts in WDEQ-LQD and NRC Documents 

(Page 2 of 5) 
2.0 PROPOSED ACTION AND ALTERNATIVES

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Table 2.2-1 Cross-References to Environmental Protection 

Measures and Impacts in WDEQ-LQD and NRC Documents (Page 3 

of 5)
2.0 PROPOSED ACTION AND ALTERNATIVES

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Table 2.2-1 Cross-References to Environmental Protection 

Measures and Impacts in WDEQ-LQD and NRC Documents (Page 4 

of 5)
2.0 PROPOSED ACTION AND ALTERNATIVES

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Table 2.2-1 Cross-References to Environmental Protection 

Measures and Impacts in WDEQ-LQD and NRC Documents 

(Page 5 of 5)
2.0 PROPOSED ACTION AND ALTERNATIVES

The baseline conditions for these resources are described in Section 3.0 (Affected 

Environment). For easier reference, the agency-required measures and 

monitoring and the impacts are summarized, by resource, in Section 4.0. For 

each resource, the agency-required and additional measures are discussed first, 

followed by discussion of monitoring, impact significance criteria, and impacts. 

The Proposed Action was analyzed with reference to the provisions of the 1872 

Mining Law, the 43 CFR 3809 regulations, and the Rawlins RMP (BLM, 2008c). 

Based on the BLM’s review and on comments received during the NEPA process,

some additional measures would be needed to address concerns not previously 

addressed through the other processes. These measures are listed in Table 2.2-2

and are included in the respective resource discussion in Section 4.0.

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Table 2.2-2 Additional Measures (Page 1 of 2) 

Resource Aspect Description of Measures 

Surface Ephemeral Surface disturbing activities would be avoided 

Water Drainages within 20 feet of the inner gorge of ephemeral 

channels identified on Figure 3.5-1 or 

identified in the field by best professional 

judgment as a channel that meets the BLM 

guideline criteria of a “defined channel formed 

in response to ephemeral surface conditions.” 

Exceptions to this would be granted by the 

BLM based on an environmental analysis and 

site-specific engineering and mitigation plans

as required per 43 CFR 3809.411(d)(2). Only

those actions within areas that could not be 

avoided and that would provide protection for 

the resource identified would be approved.

Groundwater Stability 

Monitoring

As part of the reclamation plan and associated 

monitoring, required per the 43 CFR 3809

regulations, at least two additional stability 

monitoring samples would be collected, once 

every three months over a six-month period, 

after the initial stability period. The

monitoring information would also support 

combined agency review of current stability 

monitoring requirements.
2.0 PROPOSED ACTION AND ALTERNATIVES

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Table 2.2-2 Additional Measures (Page 2 of 2) 

Wildlife –

Greater 

sage-grouse

Adaptive 

Management

To ensure continued coordination and 

consultation with other local, state, and federal 

agencies and consistency with other agency 

plans, policies, and agreements, a Technical 

Advisory Committee (BLM, WGFD, and LCI) 

would be established to develop the Adaptive 

Management Plan to complement on-going

baseline data collection and existing 

stipulations.

Wildlife Fencing Fencing around the Storage Ponds would be 

upgraded to Type II fencing (WDEQ Guideline 

No. 10 [1994c]) to preclude deer, antelope and

elk.

Wildlife Fencing New fence construction would be authorized 

according to BLM standards unless modified 

following consultation with affected parties. 

All fencing would be wildlife-friendly fencing, 

with appropriate collision deterrents, with the 

exception of the fencing around the Storage 

Ponds, which would be exclusion fencing.

Wildlife Storage Ponds If selenium levels were to reach 0.02 mg/L, or 

above, in the Storage Ponds, mitigation 

measures would be put in place to prevent 

birds from using the Storage Ponds. The 

mitigation measures used would be approved 

by the BLM, and would be monitored for 

effectiveness in preventing mortality of any 

protected birds in accordance with federal and 

state regulations, as required per 43 CFR 

3809.401(b)(4).

Wildlife Storage Ponds The BLM would require the applicant to obtain 

a Pesticide Use Proposal with associated 

environmental analysis and consider other 

Integrated Pest Management techniques, prior 

to authorizing the use of pesticides.

Wild Horses Access

Fenced

to

Pattern 

To help protect healthy herds of wild horses,

LCI would work with the BLM to determine if 

Areas an automatic gate or pitless cattle guard would 

help deter wild horse access to a pattern area if 

the pattern gate were inadvertently left open. 

Visual and 

Scenic 

Resources

Building 

Completion

To help maintain the overall objectives of 

visual resource class, paint colors would 

conform with BLM Standard Environmental 

Color Chart CC-001.
2.0 PROPOSED ACTION AND ALTERNATIVES

2.3 Alternatives Development 

NEPA requires evaluation of a No Action Alternative and reasonable alternatives 

to the Proposed Action that may avoid or minimize Project impacts. A reasonable 

alternative is defined by NEPA as one that is technically, economically, and 

environmentally practical and feasible (BLM, 2011g). With the exception of the 

No Action Alternative, alternatives would need to meet the Project’s objective of 

producing an estimated six million pounds of uranium over an operating period of 

12 years. Several alternatives were identified from the BLM’s review of the 

Proposed Action and from the issues and concerns raised from public scoping 

comments and in collaboration with cooperating federal, state, and local agencies, 

as well as tribal governments. As previously noted in Section 1.5, the public 

scoping period for this EIS was in February/March 2011. Two cooperating 

agency meetings were held in March and September 2011. In addition, public 

scoping and comment periods as well as meetings with federal, state, and local 

agencies and authorities were held for the NRC GEIS (2009) and SEIS (2011a). 

The alternatives that were considered and evaluated in detail include: 

x No Action Alternative (also evaluated in the NRC SEIS [2011a]); 

x Not Fencing the Pattern Areas; and 

x Drying Yellowcake On-Site (also evaluated in the NRC SEIS). 

Alternatives considered but eliminated from detailed study include: 

x Portable Drill Pits and Closed Loop Drilling Systems; 

x Alternative Mining Methods (also an alternative eliminated from detailed 

analysis in the NRC SEIS [2011a]); 

x Alternative Waste Water Disposal Methods (discussed in the NRC SEIS); 

x Phased Development of Mine Units; 

x Alternative Lixiviants (also an alternative eliminated from detailed 

analysis in the NRC SEIS); 

x Shipping Uranium-Laden Resin; 

x Alternate Plant Sites (evaluated by LCI prior to submittal of the NRC 

license application and WDEQ-LQD permit application); and 

x Alternate Routes for the East and West Access Roads (reviewed and 

evaluated by the NRC, WDEQ-LQD, and WGFD).

2.3.1 Alternatives Evaluated in Detail 

2.3.1.1 No Action Alternative 

Under this alternative, no ISR operations would be conducted within the Permit 

Area, although activities currently on-going would continue. At the site, LCI 

would continue exploration activities, which would at least involve reclamation of 

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disturbance associated with LCI’s Drilling Notification Permit (in which less than 

five acres may be disturbed at any given time). There would be no uranium 

produced from the Permit Area and no favorable or unfavorable impacts from this 

alternative. Current land uses, including livestock grazing, wildlife habitat, 

dispersed recreation, minerals and energy development, and infrastructure, would 

not be expected to change. 

2.3.1.2 Alternative of Not Fencing the Pattern Areas 

Under this alternative, pattern areas within the mine units would not be fenced. 

Temporary fencing, however, would be installed around all of the drill pits, 

including those drilled within the mine units. Fencing would be installed around 

the Plant and Storage Ponds.

The pattern area fencing under the Proposed Action would be wildlife-friendly, to 

allow passage of smaller animals but exclude cattle and wild horses. The purpose 

of the fencing would be to reduce damage to wells and subsequent risk of spills. 

However, if the pattern areas were fenced, grazing would not be possible in those 

areas, and if a gate to the fenced area were left open, cattle or wild horses could 

be injured if they entered the area and were startled. Therefore, the alternative of 

‘not fencing the pattern area’ was evaluated in detail.

2.3.1.3 Drying Yellowcake On-Site Alternative (Preferred 

Alternative)

The BLM selects the Drying Yellowcake On-Site Alternative as the preferred 

alternative for this FEIS. The BLM’s preferred alternative is the alternative 

which the BLM believes would fulfill its statutory mission and responsibilities, 

giving consideration to economic, environmental, technical and other factors. This 

action involves drying the mineral solution into a solid yellowcake form within 

the plant. Housing the drying-packing facility within the processing plant would 

reduce shipments from the site, resulting in fewer transportation-related impacts, 

wildlife disturbances, and cleaner air quality.

Under this alternative, LCI would construct, install and operate a yellowcake 

drying-packing facility at the Permit Area. As with the Proposed Action, 

yellowcake slurry (30 to 50 percent solids) would be produced. However, the 

slurry would be filter-pressed to remove additional water, vacuum-dried, and 

packaged on-site. 

With a vacuum dryer, the heating system would be isolated from the yellowcake 

so no radioactive materials would be entrained in the heating system or its 

exhaust. The drying chamber that contains the yellowcake slurry would be under 

vacuum, so that any potential leak would cause air to flow into the chamber rather 

than out. Drying would take place at relatively low temperatures. Emissions 

from the drying chamber would normally be treated through a bag filter to remove 

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2.0 PROPOSED ACTION AND ALTERNATIVES

yellowcake particulates; and any water vapor exiting the drying chamber would 

be cooled and condensed. 

The dried product (yellowcake) would be removed from the bottom of the dryer 

and packaged in drums for eventual off-site shipping for the next step in the 

production of fuel for commercial nuclear power plants. The packaging area 

would have a bag filter dust collection or comparable filtering system (e.g., 

HEPA, cyclone) to protect personnel and to minimize yellowcake release. An 

independent stand-alone filtration system would be used to remove particulates 

from the air that would allow for better employee protection and flexibility. 

During drum loading, the drum would also be kept under negative pressure via a 

drum hood with a suction line. The final, dried product would be cooled, 

packaged and shipped in 55-gallon drums. 

Prior to constructing, installing and operating a yellowcake drying-packing 

facility, the NRC License and WDEQ-LQD Permit to Mine would both require 

modification with review and approval by those agencies. LCI notified the NRC 

in April 2011 of its intent to request an amendment to its NRC License to install a 

rotary vacuum dryer, and the application was submitted to the NRC in January 

2012 (LCI, 2012). Use of a dryer would provide an economic benefit to the 

proponent because payment of processing fees to another operator would not be 

necessary. Use of a dryer would also result in fewer shipments from the site due 

to the difference in volume between yellowcake slurry and dried yellowcake. 

Fewer shipments would reduce traffic impacts, including the risk of transportation 

accidents and wildlife disturbance and collisions, and also reduce air quality 

impacts from travel on unpaved roads. The condensate volume from the dryer 

would be minimal and re-used in processing or disposed of through the disposal 

system used during slurry production. 

2.3.2 Comparative Summary of Impacts 

Table 2.3-1 presents a summary of the impacts of the Proposed Action and the 

alternatives evaluated in detail. Section 4.0 provides discussion of the impacts, 

protective measures, and monitoring for each resource. 

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2.3.3 Alternatives Considered and Eliminated from Detailed 

Study 

The following alternatives and management options were considered but were 

eliminated from detailed analysis as either unreasonable or impractical because of 

technical, legal, or policy considerations. Some other concepts were raised as

potential independent alternatives, but were subsequently considered to be 

required stipulations, mitigation, or incorporated as part of another alternative. 

These alternatives and concepts were developed through interdisciplinary team 

meetings, meetings with agencies, and input received during public scoping. 

2.3.3.1 Portable Drill Pits and Closed Loop Drilling Systems 

Either portable above-ground metal tanks or excavated pits are used to circulate 

the drilling mud and allow drill cuttings to settle out of the mud. The aboveground metal tanks are usually referred to as portable drill pits. Closed loop 

drilling systems are an enhancement of the portable drill pits in that these systems 

allow for additional separation of drill cuttings from the mud. For simplicity in 

the following discussion, the above-ground tanks and closed loop drilling systems 

are referred to as portable drill pits. Components of the portable drill pits may 

include shakers, baffles, settling basins, centrifuges, and suction basins for 

separating the drill cuttings from the drilling mud. Depending upon the size and 

configuration of these components, they may be divided among two or more 

tanks. Depending on the required capacity of the portable drill pits, a flatbed 

trailer and additional equipment for loading and unloading the trailer may be 

required to transport the portable drill pits to the Permit Area and between drill 

holes. Some portable drill pits have bottom rails that allow them to be skidded 

from one drill hole to the next, providing the distance is short. Other portable 

drill pits are wheel-mounted, and smaller pits may be towed behind a pickup 

while larger pits would need to be towed with a tractor-trailer. For a portable drill 

pit of comparable capacity to the excavated pit in the Proposed Action, it is likely 

a flatbed trailer or tractor-trailer would be needed. 

Portable drill pits were considered as an alternative to the excavated drill pits 

described for drilling the pattern areas and monitor wells in the Proposed Action 

(Section 2.1.2.3) as a potential way to reduce overall surface disturbance. After 

analysis, the use of portable drill pits was not evaluated in detail due to four 

primary concerns, which are discussed in the following subsections. 

While portable drill pits have proven advantageous for much larger oil and gas 

drilling operations (and in some instances for individual water wells), their 

application to ISR drilling would not be as advantageous. Oil and gas mud pits 

are generally 0.3 acres or larger in size, as needed to handle the large volumes of 

drill mud and cuttings, and are open for months. ISR pits are significantly smaller 

(e.g., 0.003 acres [Figure 2.1-7]) and are open for a few days. Also, ISR drilling 

fluids and cuttings do not contain the oily/briny materials of concern in oil and 
2.0 PROPOSED ACTION AND ALTERNATIVES

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gas drilling. In addition, the safety advantage (reduction of gas kicks) in closed 

loop drilling for oil and gas is generally not a concern for ISR drilling. Surface 

reclamation, including topsoil replacement and vegetation re-establishment, has 

generally not been problematic at ISR projects where conventional mud pits were 

used, provided proper practices for topsoil protection and pit reclamation are 

followed during drilling and operation (e.g., stripping and stockpiling topsoil and 

timely revegetation of disturbed areas as required per the WDEQ-LQD Permit to 

Mine and mitigation measures in this EIS). The BLM and WDEQ-LQD site 

inspections, the annual report reviews, and the WDEQ-LQD permit revision 

process also provide an opportunity to consider future changes in drilling 

technology and associated mud and cuttings handling practices. 

Analysis of Surface Disturbance Reduction 

The acreages of vegetation and topsoil disturbance related to the Project are 

detailed by facility (e.g., Plant, Mine Units) in Table 4.5-1 and discussed in detail 

in Sections 4.5 (Soil) and 4.8 (Vegetation). As a conservative approach, based on 

experience at other ISR operations, vegetation disturbance includes areas on 

which vegetation is crushed, but not removed, as well as areas from which 

vegetation is removed. Therefore, there would be no change in the total 

vegetation disturbance because the portable mud pits and associated equipment 

would have similar impacts to the other drilling equipment. With respect to 

topsoil removal, topsoil would be removed and replaced from about 14 acres total 

for the mud pits at the monitor wells outside the pattern areas and from about 21 

acres total for the mud pits in the pattern areas. Therefore, the potential difference 

in acreage of topsoil removal if portable mud pits were used, assuming off-site 

disposal of the drill fluids and cuttings, would be about 35 acres (less than 10 

percent of the total acreage disturbance for the Project). If the drilling fluids and 

cuttings are disposed of on-site, the potential acreage difference would be less 

than 35 acres because of the need for topsoil removal at the disposal site. 

LCI proposes using up to ten drilling rigs for mine unit development (drilling and 

installing injection wells, production wells and monitor wells) with additional rigs 

for exploration and delineation drilling. One portable drill pit would be required 

per drilling rig. Even if one larger pit could be placed at a central location for 

drilling more than one well (e.g., in the pattern areas), the need for longer hoses 

from the pit to the well locations increases the risk of spills and leaks and 

increases surface disturbance as the hoses are moved between holes. Although 

topsoil stripping might not be required for portable drill pits initially, the weight 

of the equipment and the additional traffic to place, clean out, and remove the 

portable drill pits could result in topsoil compaction and could result in 

requirements for removal of topsoil for subsequent drilling. 

The drill cuttings and some or all of the drilling mud must be disposed of as the 

portable drill pit is filled. If this material is disposed of by drying and burying at a 

designated location on-site, additional surface disturbance and wildlife exclusion 
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would be needed at that location for the life of the Project. Therefore, using the 

excavated mud pits results in less surface disturbance than use of the portable 

mud pits and an on-site drying and disposal location. 

The other concerns identified with respect to the Project-wide use of portable mud 

pits relate to transportation, wildlife, and logistics. These concerns are discussed 

below. 

Transportation 

If portable drill pits were used, the amount of equipment and personnel required 

on-site would increase. Initially, the portable drill pits and associated equipment 

would need to be brought to the site, and then would need to be moved with the 

drill rigs. In addition, the drilling mud and cuttings would need to be cleaned out 

of the portable drill pits, e.g., with a vacuum truck, dried, and disposed of at 

designated locations on-site and/or off-site. Alternately, the portable drill pits 

would need to be removed from the drill site and emptied at a designated location 

on-site or off-site. During installation of the pattern area, about 1.5 wells would 

be completed per day. The disposal of drilling mud and cuttings may require 

more than one trip per day from each well, depending on the portable pit size and 

subsurface conditions. Most vacuum trucks have capacities from 3,000 to 5,000 

gallons. Presuming the larger trucks are available, then at least 1.5 trucks per day 

would be needed if the portable drill pits were of similar size to the excavated pits 

and depending on how much of the drilling mud could be reused. As not all of 

the wells would be finished on different days, a more realistic scenario would be 

an additional two to three trucks per day. 

The potential increase in on-site traffic associated with the use of portable mud 

pits, the subsequent increase in emissions and the potential for more accidents, 

particularly with the equipment proximity in the pattern areas, are considered to 

weigh against any potential benefit if surface disturbance were reduced. 

Wildlife 

The potential increase in on-site traffic associated with use of portable mud pits 

could also increase the risk of wildlife injury or mortality due to collisions. 

Similarly, if the drilling fluids and cuttings were disposed of off-site, the increase 

in traffic to and from the site would also increase the potential for wildlife 

collisions. 

Another concern pertaining to wildlife is the need for additional exclusion areas. 

The use of a centralized location for drying and disposal of the drill cuttings is 

considered more problematic than the use of excavated mud pits with respect to 

wildlife exclusion. Mud pits for the monitor wells and in the pattern areas are 

generally open less than a week. They are fenced while open, and then backfilled 

and topsoil is reapplied. In addition, they are usually in areas where there is 
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considerable human activity, deterring wildlife presence. A centralized disposal 

site would essentially be open for several years, which would require fencing,

deterrence for birds, and similar measures to exclude wildlife from the disposal 

site. 

Logistics

With respect to logistics, rig and driller availability have been at a premium in 

Wyoming, and the specialized equipment would further restrict the equipment and 

contractor availability and would increase costs. 

In addition, during cold weather, keeping fluids in any additional above-ground 

equipment, such as tanks and hoses, from freezing would add to the drilling time 

and fuel use. 

2.3.3.2 Alternative Mining Methods 

Methods used to extract uranium resources include ISR mining, open pit mining, 

and underground mining. ISR mining is commonly used to recover uranium from 

low-grade ores where other mining and milling methods may cause significant 

environmental impacts or may not be economically feasible. As described in 

Section 2.1.1, ISR mining (otherwise known as ‘solution’ mining) involves 

injecting a lixiviant through a series of wells installed in the ore body. The 

lixiviant dissolves the uranium in the ore body. The resulting uranium-laden 

solution is then pumped to the surface through production wells. After moving 

through pipelines, the uranium in solution is then recovered in a processing plant. 

Open pit mining and underground mining methods, which are described below, 

were considered as alternatives to ISR mining. 

Open Pit Mining 

Open pit mining requires the removal of all material covering the ore body 

(overburden) and then the ore itself. The ore would then be transported to a 

conventional mill for further processing and extraction through grinding, 

leaching, purifying, concentrating, and drying. 

From a technical standpoint, the mine pit and waste rock piles from excavation of 

the overburden would make permanent changes to the topography of the Permit 

Area (and the post-mine land uses). The pit, which would be on the order of 300 

to 700 feet deep, would require a disturbed area approximately three times the 

area of the ore body mined in order to maintain slope stability. Open pit mining 

at the Permit Area would also require substantial dewatering of the pit to depress 

the potentiometric surface of all aquifers. Large quantities of groundwater would 

be discharged to the surface. Some of this groundwater would contain naturally 

elevated radium, radon and uranium, requiring treatment before discharge, and the 

treatment residue would need to be disposed of as radioactive solid waste. 

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Potential personnel injury rates and potential radiological exposures at the mining 

site would also be higher with open pit mining than what would be experienced 

with ISR mining. 

A mill tailings pond would be required to contain the millions of tons of waste 

produced from the uranium mill. Although the mill would be at a different 

location, the additional material from the Project would contribute to the size of 

the tailings facility. This material would represent a large volume of radioactive 

tailings slurry covering a large area of ground surface. Conventional mill 

operation would involve higher risks of spillage and radiological exposure to both 

personnel and the environment than those associated with the proposed ISR 

operations. 

Underground Mining 

Underground mining of the uranium resources at the Permit Area would involve 

sinking of shafts to the vicinity of the ore bodies, horizontally driving crosscuts 

and drifts to the ore bodies at different levels, physically removing the ore, and 

transporting the mined ore to a conventional mill for further processing. 

Processes for milling and uranium extraction from underground mined ores would 

be the same as those for ores mined from the open pit. 

The technical disadvantages of underground mining closely parallel those of open 

pit mining. These, as stated above, include permanent changes to the topography 

(though in a smaller scale than open pit mining because less amounts of waste 

rock would be generated), generation of a significant amount of water and mine 

tailings, increased risks of injury and potential exposure to radioactive materials 

during mining and milling, and large amounts of initial investment. 

Another major concern for underground uranium mining is the potential exposure 

of miners to radon gas if the gas was not continuously vented to the atmosphere. 

Land surface subsidence could also occur after the completion of underground 

mining. 

Because of the potential for additional risks to human safety, a greater amount of 

surface disturbance and other environmental impacts, and greater need for 

reclamation, Alternative Mining Methods were not considered in detail. 

2.3.3.3 Alternative Waste Water Disposal Methods 

The liquid process waste generated from uranium ore processing is an 11(e)(2) 

byproduct material. The Project would generate about 105 gallons of liquid 

process waste per minute, primarily from the production and eluate bleeds and the 

yellowcake wash water. The production bleed would generate between 30 and 90 

gpm, totaling 100 gpm when combined with the restoration discharge. An 

additional 5 gpm would be generated from the eluate bleed and yellowcake wash 
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water. Laboratory analyses of the production fluid would produce another 25 

gallons per day (Operations Plan, WDEQ-LQD Permit to Mine [LCI, 2011b]). 

Two alternative waste water disposal methods, evaporation ponds and land 

application, were considered. 

Evaporation Ponds 

Solar evaporation ponds are an alternative to the UIC Class I wells described in 

the Proposed Action. The primary function of the evaporation ponds would be to 

provide temporary storage of the liquid process waste as it is allowed to evaporate 

from natural solar radiation. The evaporation ponds must be designed to provide 

adequate storage with sufficient freeboard and must have liners that are designed, 

constructed, and installed to prevent any migration of wastes to the adjacent 

subsurface soil, groundwater or surface water during the active life of the ponds. 

A leak detection system must be installed immediately below the liner and a 

groundwater monitoring program must be established in accordance with the 

groundwater protection standards established by the EPA in 40 CFR Part 192, 

Subpart D and E. 

The capacity of the evaporation ponds must account for the evaporation rate 

compared to the total liquid (liquid process waste plus precipitation) input into the 

ponds. In addition, evaporation rates would need to be determined for the liquid 

process waste. It has been demonstrated that fresh water evaporation rates 

decrease as the amount of solids and chemical concentrations increase in the 

solution (Pochop et al., 1985). An evaporation pond design based solely on fresh 

water evaporation rates may fail at some point due to overtopping. 

The design of the evaporation ponds must provide resistance to wind and water 

erosion during the Project operations. The planning, siting, and design of the 

evaporation ponds are described by the NRC in 10 CFR Part 40, Appendix A. 

The design, construction, and inspection of embankment retention systems at 

Uranium Recovery Facilities are described in NRC Regulatory Guide 3.11 

(2008a). The siting and design must also follow applicable EPA requirements 

contained in 40 CFR Part 264. 

The construction and operation of evaporation ponds involves additional land 

disturbance compared to ISR. Based on the estimated production rate of 105 gpm 

of liquid process waste and an estimated average annual evaporation rate of 42.5 

inches determined for Pathfinder Dam (Pochop et al., 1985), the minimum total 

pond area would be 40 acres. The area would also require exclusion fencing. 

Productivity and efficiency would also be an issue. Due to the severe winter 

weather conditions at the Permit Area, the evaporation ponds would be frozen and 

covered with snow for several months, making any evaporation close to 

impossible. In addition, the solid wastes that precipitate from the process water 

would be radioactive and extensive efforts would be needed during the 
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reclamation phase to clean up and dispose of these solid wastes. Sludge 

accumulation could also decrease the useful life of the evaporation ponds. 

Land Application 

An alternative to the UIC Class I well liquid process waste disposal method is 

land application. Land application uses irrigation equipment to discharge treated 

process water to the land surface. The process water would have to be treated in 

accordance with the requirements contained in NRC 10 CFR Part 20, Subparts D 

and K and Appendix B before being broadcast onto the land surface. The treated 

process water would have to meet the requirements of WYPDES, and the 

NESHAP regulations contained in NRC’s 10 CFR Part 61. A regular monitoring 

program would be required to ensure that soil loading and vegetation 

concentrations fall within the permit limits. 

As with the evaporation ponds, severe winter conditions in the Permit Area would 

limit the efficiency of land application. Storage of the water would be necessary 

during the winter months. This would require an additional storage pond to hold 

the treated water during the winter months. 

Since evaporation ponds and land application involve additional surface 

disturbance or impacts and are not practical considering the weather conditions of 

the Permit Area, these Alternative Waste Water Disposal Methods were not 

considered in detail. 

2.3.3.4 Phased Development of Mine Units 

A mine unit consists of ISR amenable production zones within a sandstone 

bounded by upper and lower hydrologic barriers. In the simplest scenario, a 

monitor well ring radially bounds the injection and production wells in the ore 

zone as one of the primary means of ensuring control of mining solutions within a 

mine unit. Monitor wells are also completed in underlying and overlying zones to 

ensure no vertical movement of fluid from the production zone (Figure 2.1-4). 

Mine units (and even the header houses within the mine units) are developed, 

produced, and reclaimed sequentially, i.e., the Proposed Action proceeds in 

phases. Two approaches to defining the phases were considered, one of which is 

primarily technical and the other of which is primarily regulatory. The first 

approach relates to the scale of the mine units, and the second approach relates to 

whether the phases are ‘schedule-based’ or ‘standard-based’. 

Scale of the Mine Units 

The scale of the mine units for a given ISR operation depends on a variety of 

factors, including ore distribution, aquifer characteristics, plant capacity design, 

and operational feasibility. An alternative to the three mine units in the Proposed 

Action is the installation of larger or smaller mine units. Under the larger mine 
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unit scenario, there would be fewer mine units but more wells and associated 

production equipment per mine unit. Under the smaller scale mine unit scenario, 

there would be more mine units but fewer wells and associated production 

equipment per mine unit. For a larger mine unit, the time required for the 

activities associated with developing, producing, and reclaiming the mine unit 

would increase dramatically. Conversely, for a smaller mine unit, the time 

required for all activities associated with developing, producing, and reclaiming 

the mine unit would decrease. For a smaller mine unit, operation may not be 

feasible, e.g., due to increased potential for interference in ore production and 

groundwater restoration based on the aquifer conditions. In addition, from an 

economic standpoint, more mine units would need to be in operation at any one 

time under the smaller mine unit scenario. 

Based on the aquifer testing conducted by LCI (Appendix D6 of the WDEQ-LQD 

Permit to Mine and Attachment MU1 2-1 of the WDEQ-LQD Mine Unit 1 

documents [LCI, 2011b]), the ore distribution in the HJ Sand (Appendix D9 of the 

WDEQ-LQD Permit to Mine [LCI, 2011b]), operational feasibility, and WDEQLQD regulatory review, three mine units are currently considered the best 

approach to efficient mining and resource protection. Initially, the Project 

included six mine units in the same area as the three mine units. However, as 

described in Project Development of the Adjudication File of the WDEQ-LQD 

Permit to Mine (LCI, 2011b), consolidation to three mine units was considered 

more appropriate. 

Regardless of the number of mine units in the Permit Area, the total disturbance 

area does not change because the footprint of the mine units follows the ore trend. 

Therefore, this alternative was not evaluated in detail. Due to the relatively short 

timeframe of the Project, the total disturbance area of the Project is considered 

rather than staged disturbance areas of the mine units when evaluating potential 

Project-related impacts and mitigation measures (Section 4.0).

Schedule-Based versus Restoration-and/or-Reclamation-Based Phases 

In the Proposed Action, the schedule provides a basis for the Project phases. 

Similar to the requirements of other mining operations (e.g., coal), 

contemporaneous reclamation would be performed. For example, one mine unit 

would be in the Reclamation phase at the same time another mine unit would be 

in the Construction phase or Operation phase. However, in order to comply with 

the schedule, certain targets would be met for groundwater restoration, surface 

reclamation, and other aspects of the Project. 

The proposed Project schedule and supporting information (e.g., the water 

balance and restoration rates) were reviewed by the WDEQ-LQD and the NRC. 

At least annually, LCI would review and revise the schedule and the WDEQ-LQD 

Permit to Mine as necessary to reflect the current Project status. These revisions 

would be reported to the WDEQ, the NRC, and the BLM in LCI’s Annual Report. 
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Per WS §§35-11-411(a)(ii)(C) and 411(b), WDEQ-LQD may require information 

from LCI on schedule adjustments and permit revisions, and may object to the 

information provided in the Annual Report. In accordance with the 2005 rule 

changes, the WDEQ-LQD also reviews the permit once every five years to 

determine if any changes are necessary (WDEQ-LQD NonCoal Rules and 

Regulations Chapter 11, Section 18(b) [2005b]). Provisions are also included in 

the Proposed Action for review and approval of new mine units before installation 

and operation (Section OP 3.2, WDEQ-LQD Permit to Mine [LCI, 2011b]). Per 

the MOU between the BLM and the WDEQ-LQD (2003), concerns raised by 

either agency about an operation shall be communicated to the other. 

A suggested alternative to using the schedule as the basis for the phases would be 

to use only groundwater concentrations and/or vegetation re-establishment 

criteria. To meet groundwater concentration and/or vegetation re-establishment 

criteria, a mine unit would be required to complete (or nearly complete) 

groundwater restoration and/or reclamation prior to the development or operation 

of another mine unit. In other words, operation of a new mine unit could not 

commence until groundwater restoration and reclamation were completed for the 

previous mine unit in accordance with the requirements contained in Sections RP 

2.0 and 4.5 of the WDEQ-LQD Permit to Mine (LCI, 2011b). This alternative 

was suggested because of concerns about lengthy restoration times, in excess of 

the permitted schedule, in previous ISR operations. However, the regulatory 

mechanisms to address such lapses are in existence, as outlined in the previous 

paragraph. In addition, the lapses in previous ISR operations were not directly 

attributable to inadequate restoration methods, rather to the delays in 

implementing restoration in favor of production. In addition, more rigorous 

aquifer testing, mine unit balancing, and regulatory review are in place than when 

the older operations were first approved more than 20 years ago. 

A critical component is that this alternative (groundwater concentrations and/or 

vegetation re-establishment criteria as the basis for the phases) would not be 

economically viable and would constrain some of the available technical options 

for more efficient mining and groundwater restoration. Most mining projects 

require a relatively high initial outlay of capital. However, subsequent operations 

are a balance of income (mining) and expense (operating, maintenance, and 

reclamation) throughout the life of the mine until the final removal of the mine 

facilities. With this groundwater and/or vegetation criteria alternative, the Project 

would alternate between periods of income and expense (during mining) and just 

expense (during restoration), which would be contrary to the requirements for 

other mining operations, e.g., coal, in which contemporaneous reclamation is 

required, but not complete closure of one mine pit before starting another. 

Using the criteria in Figure 2.1-8, groundwater restoration would be required in 

one mine unit before development of the next mine unit, there would be a twoyear hiatus between Mine Units 1 and 2 because that is the elapsed time for 

restoration of Mine Unit 1. There would be a four-year hiatus between Mine 

Units 2 and 3; the hiatus would be longer because Mine Unit 2 is anticipated to be 
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larger than Mine Unit 1. This would extend the schedule, and associated 

disturbance, from 11 years to 17 years. The income-generating portion of the 

Project, i.e., Production, would still take place during six years, less than one-half 

the Project life. Currently, Production would take place during about two-thirds 

of the Project life. (If surface reclamation were required in one mine unit before 

development of the next mine unit, the hiatus between mine units would be even 

longer to allow for revegetation after groundwater restoration.) Even if some or 

all of the Plant, offices, disposal wells, and associated equipment could be 

‘mothballed’ and restarted without undue maintenance or replacement expenses, it 

is unlikely that a skilled employee base could be retained throughout the Project 

life as the number of employees needed would vary radically. Similarly, it would 

be difficult for LCI to effectively negotiate supply or sales contracts if the need 

for supplies or the amount of yellowcake produced varied substantially over the 

life of the Project. The income to municipalities, counties, and the state would 

also vary, making it more difficult for them to effectively plan for services. 

From a technical standpoint, a hiatus between mine units for completion of 

groundwater restoration or revegetation raises several concerns. First, the option 

for groundwater transfer (or exchange) between a mine unit in restoration and 

another mine unit in production is no longer available. This option, which is 

discussed in more detail in Section RP 2.3.1 of the WDEQ-LQD Permit to Mine 

(LCI, 2011b), allows for some reduction in consumptive use of groundwater, a 

reduction which would no longer be available. Second, revegetation would be ‘on 

hold’ in some areas because of the overlap of facilities. As currently envisioned 

(Figure OP-2a of the WDEQ-LQD Permit to Mine), Mine Unit 3 would share 

some of the same road and pipeline access as Mine Unit 1; therefore, some of that 

area would remain disturbed for twice as long as currently planned. This would 

also require that the associated topsoil stockpiles, erosion protection measures, 

and weed control would need to be in place for longer than currently planned. 

Third, the reclamation 'bond clock' for revegetation is a minimum of five years; 

however, circumstances beyond LCI's control, such as drought or fire, could 

extend this time frame, making it even more difficult to plan for the time lapse 

between mine units. 

In essence, the schedule-based approach in the Proposed Action would include the 

specific restoration and reclamation parameters along with how they would be 

evaluated (e.g., Section 6.1.3 of the WDEQ-LQD Mine Unit 1 document [LCI, 

2011b]) and would allow for the evaluation of other considerations in determining 

whether the operation is progressing as planned. Therefore, the schedule-based 

approach is considered effective and is economically practicable. 
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2.3.3.5 Alternative Lixiviants 

Since uranium is soluble under both acidic and alkaline conditions, it is possible 

to use either acid or alkaline based lixiviant reagents. The main criteria for using 

acid or alkaline leaching agents are: 

x Potential or desired rates of dissolution or the rate that uranium enters

solution; 

x Effects of leaching solutions on aquifer formation properties (such as 

aquifer permeability reduction); 

x The cost of the chemicals and associated safe-handling practices; 

x The reactions between leaching solutions and gangue minerals; and 

x The requirement (and ability) to restore groundwater quality to pre-mining 

levels after the completion of ISR mining (Mudd, 1998). 

For acid uranium leaching, sulfuric acid is the cheapest and most common acid 

used, although it has rarely been used in the US. Hydrochloric acid and nitric 

acid could also be used but at a much higher cost. The oxidizing agents used in 

conjunction with acid leaching include sodium chlorate, oxygen, manganese 

dioxide, and ferric sulfate (Mudd, 1998). 

Alkaline leaching agents include carbon dioxide, sodium carbonate-bicarbonate, 

and ammonium carbonate-bicarbonate. Common oxidizing agents include 

hydrogen peroxide and oxygen (Mudd, 1998). 

The advantage of acid leaching is achieving higher extraction of uranium in a 

shorter timeframe. Acid leaching also results in the dissolution of higher 

concentrations of gangue minerals, but the migration of the dissolved ions is 

limited by the natural neutralization of the acid. Alkaline leaching introduces 

fewer ions into solution; however, dissolved ions can migrate further (Taylor et 

al., 2004). Alternative lixiviants, such as sulfuric acid or ammonium carbonate 

solutions, are being used in other countries and have been used in the past at ISR 

operations in the US. However, they are not currently used in Wyoming because 

of the geochemical conditions and difficulties in restoring and stabilizing the 

affected aquifers. Furthermore, the composition of the ore-bearing sandstones in 

the Permit Area (i.e., relatively high carbonate content) makes acid lixiviants not 

technically feasible. Ammonia-based lixiviants are generally not used because 

the ammonia tends to adsorb onto clay minerals in the subsurface and then slowly 

desorb from the clay during restoration, requiring larger amounts of groundwater 

to be removed and processed during aquifer restoration. For these reasons, 

lixiviants other than alkaline-based lixiviants were eliminated from detailed 

analysis. 

The Proposed Action includes the use of a sodium carbonate-bicarbonate based 

lixiviant (Section OP 3.1 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). LCI 

currently plans to use soda ash to prepare this lixiviant, although caustic soda 
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could also be used but is currently more expensive. A concern was raised as to 

the potential risks if caustic soda were used. However, caustic soda is already 

used as part of the uranium processing in the Plant (Section OP 4.3 of the WDEQLQD Permit to Mine [LCI, 2011b]), so appropriate precautions for storage and 

handling of the material are in place. The lixiviant would be prepared within the 

Plant, and once prepared, would not be different than the lixiviant prepared using 

soda ash. Therefore, different preparations of the sodium carbonate-bicarbonate 

based lixiviant have not been evaluated separately. 

2.3.3.6 Shipping Uranium-Laden Resin 

The uranium can be shipped off-site in three different forms, uranium-laden resin, 

yellowcake slurry, or dried yellowcake, depending on the extent of processing. 

After ion exchange, which is the first process circuit in the Plant, the uraniumladen resin could be shipped off-site for additional processing to produce dried 

yellowcake. After the precipitation/filtration circuit, the third process circuit, the 

yellowcake slurry could be shipped off-site for additional processing to produce 

dried yellowcake. 

Shipping uranium-laden resin is a standard industry practice for satellite 

processing plants in conjunction with processing facilities. At the satellite 

processing plant, uranium is oxidized, mobilized and pumped out of the sandstone 

formation into a loaded pipeline and ends up in ion exchange columns. Inside the 

columns, uranium is extracted through an ion exchange process - a chloride ion on 

a resin bead exchanges for a uranium ion. After the fluid has been stripped of 

uranium, it is sent back to the mine unit as barren solution, minus the bleed. 

Uranium is adsorbed onto negatively charged polymer or plastic particles in the 

ion exchange columns. When the resin beads in the ion exchange columns 

become saturated with uranium, the columns are taken offline and the loaded 

resin is transported by truck to a central uranium processing facility. 

Semi-trailer trucks hauling the loaded resin carry modified bulk cement trailers 

with three compartments. The three compartments, or cells, each have a function. 

One cell holds the uranium-loaded resin, one cell is empty and the third has 

unloaded resin. As per DOT regulations, no liquids are permitted during the 

transportation process (Finch, 2007). 

LCI anticipates a production rate of one million pounds U3O8 per year. The 

average load of resin would be 500 cubic feet at a loading rate of eight pounds per 

cubic foot, or 4,000 pounds U3O8 per transfer (load). This would require a 

shipment of loaded resin to a separate facility approximately every 1.5 days. In 

the Proposed Action, the Project would process slurry and require the transport of 

approximately 15,000 pounds U3O8 to a drying facility at a time. This would 

require a shipment every 5.5 days. Therefore, for the above reason, the option of 

shipping loaded resin for processing and drying was eliminated. 
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2.3.3.7 Alternate Plant Locations 

Prior to 2007, two locations were considered for the Plant based on the 

information available at the time. The location which was selected, the ‘northern’ 

location is in the Northwest Quarter of the Southeast Quarter of Section 18, 

Township 25 North, Range 92 West. The other location, the ‘southern’ location 

was in the Northeast Quarter of the Southeast Quarter of Section 19, Township 25 

North, Range 92 West. The northern location was selected based on several 

criteria. First, the results of exploration drilling indicated the southern location 

could interfere with potential mine unit development. Second, the southern 

location was within a drainage area. Third, both locations were about equidistant 

to Greater sage-grouse leks, but the southern location was closer to active raptor 

nests. Fourth, the potential radiation risk to the public was slightly higher at the 

southern location. Therefore, by the time the license application and related 

documents were submitted to the NRC and the WDEQ, the northern location was 

incorporated into the Proposed Action and the southern location was omitted from 

further consideration (LCI, 2008 and 2011b). 

2.3.3.8 Alternate Routes for the East and West Access Roads 

The access routes to the Permit Area must satisfy requirements of the County, the 

State, the BLM, and the NRC, including: 

x For emergency purposes, Sweetwater County requires two access roads 

for ingress and egress (LCI, 2011a). 

x The BLM and the State require that roads meet specific design criteria, 

depending on road usage, to minimize soil loss and surface water impacts 

from erosion. For example, culverts may be required on some stream 

crossings. Road treatments to reduce dust or improve traction must also 

be identified. 

x The BLM and the State require that routes for new or improved roads 

address soil and vegetation impacts, including identification of soil types 

and vegetation, to minimize disturbance of sensitive areas. 

x The BLM and the State require that the impacts of roads on wildlife be 

identified and mitigated. In particular, the impacts on Greater sage-grouse 

and raptors are of concern. 

x The NRC requires the evaluation of environmental and safety aspects of 

the roads with particular attention to radiation concerns. 

Sweetwater County has determined the Project’s transport routes provide 

adequate access with regard to fire and safety; and the County and LCI are 

working on a maintenance agreement to ensure adequate access. The NRC, the 

WDEQ-LQD, and the WGFD have reviewed the routing of the East and West 

Access Roads and evaluated potential impacts. The NRC evaluated these 

transport routes for environmental impacts and safety in the SEIS (2011a). 

Section 4.3 provides detailed information concerning Project transport, such as 
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the number and type of vehicles, and materials transported, including equipment, 

supplies, wastes, and products. The WDEQ-LQD reviewed LCI’s Permit to Mine

for compliance with State environmental requirements (LCI, 2011b); and the 

WGFD analyzed the WDEQ-LQD Permit to Mine (LCI, 2011b) for compliance 

with the Wyoming Sage Grouse Executive Order 2011-5 (EO 2011-5) as signed 

by Governor Matt Mead (Mead, 2011). The existing routes met the criteria 

established by these agencies. However, to ensure that options for potentially 

better routes were not overlooked, alternate routes were reviewed. 

Current Routes 

As shown in Figure 2.3-1, the East Access Road is a bladed dirt road that extends 

2.2 miles from the Sooner Road to the east Permit Area boundary. In the 

Proposed Action, the East Access Road would primarily provide access to 

employees commuting from the east of the Permit Area. Some supplies, 

materials, and waste would also be transported on this road, depending on the 

origin or destination of the shipment. Figure 2.3-2 is a photograph of the West 

Access Road, which is a 2.8-mile existing two-track dirt road from the 

Wamsutter-Crooks Gap Road to the west Permit Area boundary. Both of these 

roads have existed for many years. The West Access Road was reportedly 

constructed (including ditch and crown) for access to a potential oil and gas drill 

site, but the road was not maintained and has partially filled in with soil and 

vegetation. 

In the Proposed Action, the West Access Road would provide access to 

employees commuting from the west of the Permit Area. In addition, the West 

Access Road would provide the most direct route to the railroad and to roads 

capable of accommodating large, heavy-duty trucks carrying materials, supplies, 

products, including yellowcake slurry, and waste – following the West Access 

Road west to the Wamsutter-Crooks Gap Road and south to I-80. In the Proposed 

Action, the East and West Access Roads would be upgraded for Project use 

according to seasonal restrictions and BLM standards (Section 2.1.2.5).

The major concern regarding the East and West Access Roads is their location 

with respect to Greater sage-grouse leks. The Permit Area lies within the Greater 

sage-grouse Core Area; and the East and West Access Roads pass through buffers 

for occupied Greater sage-grouse leks. The EO 2011-5 states that no roads shall 

be placed within 0.6 miles of an occupied Greater sage-grouse lek, and main 

roads used to transport production and/or waste products shall be located at least 

1.9 miles from an occupied Greater sage-grouse lek. However, the EO does allow 

for exceptions to be considered on a case-by-case basis (Mead, 2011). 
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Figure 2.3-1 Photo of the East Access Road

Looking west, 0.7 miles west of the Sooner Road, July 2009 

Figure 2.3-2 Photo of the West Access Road

Looking west, one mile east of the Wamsutter-Crooks Gap Road, July 2009 
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Figure 2.3-3 shows the relative locations of the access roads to Greater sagegrouse leks in the Permit Area. The existing East Access Road passes through the 

edge of the 0.6-mile buffer of a Greater sage-grouse lek. The existing West 

Access Road passes through the 0.6-mile buffer of two Greater sage-grouse leks. 

The proximity of the East and West Access Roads to these three leks could impact 

Greater sage-grouse use of these leks. In the consideration of the Project, the 

WGFD reviewed the potential impacts to Greater sage-grouse associated with 

upgrading the existing two-track roads and determined that upgrading the existing 

roads to provide access to the Permit Area would have less impact to the Greater 

sage-grouse than creating new roads outside the 0.6-mile lek buffer (WDEQ, 

2011a). 

The West Access Road intersects the 1.9-mile buffer of three Greater sage-grouse 

leks. To assess potential impacts from upgrading this road, topographical visual 

assessments were prepared, along with an analysis of opportunity costs of habitat 

fragmentation. The WGFD reviewed the assessments and analysis and 

determined that this option would have less impact to the Greater sage-grouse 

than creating new roads outside the 1.9-mile lek buffer (WDEQ, 2011a). 

Furthermore, the estimated production transport of one 18-wheeler truck per day 

was not expected to have significant impacts. 

Alternate Routes 

Three alternate routes were considered, as shown on Figure 2.3-3. The BLM 

considered two alternate routes to avoid the 0.6-mile Greater sage-grouse lek 

buffer and, if possible, the 1.9-mile Greater sage-grouse lek buffer. The Northern 

Alternate Access Road approaches the Permit Area from the northwest, off of the 

Wamsutter-Crooks Gap Road. The Southern Alternate Access Road is south of 

the Permit Area, from the Mineral Exploration Road. Although these routes are 

potentially viable, they are less preferable relative to the existing routes, as 

outlined below. The third alternative, the Southeast Alternate Road, was 

proposed during public review and comment on the WDEQ-LQD Permit to Mine 

Application; however, for the reasons outlined below, it was not considered 

viable. 

The Northern Alternate Access Road uses one of two existing two-track roads that 

extend northeast from the Wamsutter-Crooks Gap Road north of the proposed 

West Access Road, and then continues southeast to the Permit Area via a new 

road. This option would require the improvement of one to two miles of existing 

two-track road and the construction of three to four miles of new road. This 

option avoids the one-mile buffer around raptor nests and the 0.6-mile buffer of 

occupied Greater sage-grouse leks, but is within the 1.9-mile buffer of several 

occupied Greater sage-grouse leks. In addition, depending on the exact route, this 

road would require a new crossing over a major drainage, Eagles Nest Draw, or 

would require a new road along the more dense vegetation following the Draw. 
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The option for the Southern Alternate Access Road, off of the Mineral 

Exploration Road, includes the use of several existing two-track roads as well as 

the development of new sections of road. This alternate road would require the 

improvement of a total of three miles of two-track roads and the construction of 

approximately four miles of new road. This option does not intersect Greater 

sage-grouse lek buffers or raptor nest buffers; however, both new and existing 

roads associated with this alternative are still entirely within the Greater sagegrouse Core Area. In addition, it would require upgrading a road through the 

more dense vegetation along several draws, including Battle Springs Draw, and

upgrading several drainage crossings. Also, because the road has several twists 

and turns, the potential for accidents increases. The road could potentially be 

straighter, but this would result in essentially all new road and the subsequent 

increase in soil, vegetation, and drainage disturbance. 

During public review and comment on the WDEQ-LQD Permit to Mine, the 

Wyoming Outdoor Council (WOC) suggested the Southeast Alternate Road 

(WOC, 2011). However, this alternate route is within the 1.9-mile buffer of two 

Greater sage-grouse leks, which were not identified in WOC’s analysis. In 

addition, WOC’s alternate route is within one mile of two active raptor nests; 

therefore, a seasonal restriction would apply according to the BLM Rawlins RMP 

(2008c). Additionally, no surface disturbance can occur within 1,200 feet of an 

active nest; this alternative would violate this regulation as well. Upgrades to 

existing two-track roads and the construction of new road would be required, 

along with new drainage crossings over Stratton Draw and Battle Springs Draw. 

Therefore, this alternative was determined unsatisfactory. 

In summary, the Northern and Southern Alternate Access Roads avoid the 0.6-

mile buffer around Greater sage-grouse leks, and the Southern Alternate also 

avoids the 1.9-mile Greater sage-grouse buffer. In this respect, these alternatives 

seem preferable to the West Access Road. However, the North and South 

alternatives involve not only the improvement of existing two-track roads, but the 

development of miles of entirely new road and new drainage crossings. The 

construction of new roads disturbs previously untouched Greater sage-grouse 

habitat and contributes to habitat fragmentation, which is one of the bigger threats 

to Greater sage-grouse populations. The WGFD determined that construction of 

new roads would have a greater negative impact on Greater sage-grouse 

populations than the improvements made to existing two-track roads (LCI, 

2011a). 

Additionally, as noted in the topographical visual assessments of the West Access 

Road, the topography creates a barrier between the West Access Road and the 

nearby leks, reducing the impact this road could have on the neighboring leks. 

The WGFD examined the transportation options for the site, and believed the 

proposed East and West Access Roads to be in compliance with the EO 2011-5

(WDEQ, 2011a). If an alternative to the East (or West) Access Road were 

chosen, another impact could be the reclamation of the East (or West) Road to 
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ensure it was not used as a ‘short-cut’ for easier access to the Permit Area, 

particularly if the Northern Alternate Access Road were selected. Under the 

Proposed Action, the East and West Access Roads would both be completely 

reclaimed upon Project completion. However, the BLM would be consulted and 

given the option to retain the roads established for the Project, reclaim the roads 

to accommodate their current two-track uses, or to completely reclaim the roads 

for no vehicular use. 

For the reasons outlined above, the Northern and Southern Alternate Access 

Roads were not included for a more in-depth analysis, and the East and West 

Access Roads were included in the Proposed Action.