2.0 PROPOSED ACTION AND ALTERNATIVES

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-i 

April 2012

Table of Contents 

2.0 PROPOSED ACTION AND ALTERNATIVES .................................... 2-1

2.1 Proposed Action .................................................................................. 2-1

2.1.1 Summary of the Proposed Action .................................................. 2-1

2.1.2 Site Facilities .................................................................................. 2-5

2.1.2.1 Process Plant and Utilities .................................................... 2-5

2.1.2.2 Storage Ponds ....................................................................... 2-6

2.1.2.3 Mine Units ............................................................................ 2-8

2.1.2.4 UIC Class I Wells ............................................................... 2-11

2.1.2.5 Roads .................................................................................. 2-12

2.1.2.6 Fences ................................................................................. 2-14

2.1.3 Construction ................................................................................. 2-15

2.1.3.1 Initial Construction ............................................................. 2-15

2.1.3.2 Mine Unit Development ..................................................... 2-15

2.1.4 Operation (Production) ................................................................. 2-18

2.1.4.1 Mine Units .......................................................................... 2-18

2.1.4.2 Plant .................................................................................... 2-19

2.1.4.3 Instrumentation and Control ............................................... 2-21

2.1.4.4 Effluent Control Systems .................................................... 2-22

2.1.5 Reclamation .................................................................................. 2-28

2.1.5.1 Mine Unit Restoration and Reclamation ............................ 2-28

2.1.5.2 Final Reclamation ............................................................... 2-29

2.1.6 Schedule ....................................................................................... 2-34

2.1.6.1 Construction ........................................................................ 2-35

2.1.6.2 Operation (Production) ....................................................... 2-37

2.1.6.3 Reclamation ........................................................................ 2-38

2.1.6.4 Schedule Adjustments ........................................................ 2-45

2.1.7 Monitoring .................................................................................... 2-45

2.2 Agency-Required Measures .............................................................. 2-52

2.3 Alternatives Development ................................................................. 2-59

2.3.1 Alternatives Evaluated in Detail................................................... 2-60

2.3.1.1 No Action Alternative ......................................................... 2-60

2.3.1.2 Alternative of Not Fencing the Pattern Areas ..................... 2-60

2.3.1.3 Drying Yellowcake On-Site Alternative ............................ 2-61

2.3.2 Comparative Summary of Impacts ............................................... 2-62

2.3.3 Alternatives Considered and Eliminated from Detailed Study .... 2-77

2.3.3.1 Portable Drill Pits and Closed Loop Drilling Systems ....... 2-77

2.3.3.2 Alternative Mining Methods ............................................... 2-80

2.3.3.3 Alternative Waste Water Disposal Methods ....................... 2-81

2.3.3.4 Phased Development of Mine Units ................................... 2-83

2.3.3.5 Alternative Lixiviants ......................................................... 2-86

2.3.3.6 Shipping Uranium-Laden Resin ......................................... 2-87

2.3.3.7 Alternate Plant Locations ................................................... 2-88

2.3.3.8 Alternate Routes for the East and West Access Roads ....... 2-88
2.0 PROPOSED ACTION AND ALTERNATIVES

2-ii DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

List of Figures 

Figure 2.1-1 Lost Creek Ore Trend ............................................................ 2-2

Figure 2.1-2 Typical ISR Operation ........................................................... 2-3

Figure 2.1-3 Plant and Shop Detail............................................................. 2-7

Figure 2.1-4 Mine Unit 1 Monitoring Well Locations ............................... 2-9

Figure 2.1-5 Typical Surface Facilities in a Mine Unit ............................ 2-10

Figure 2.1-6 Road Design Features .......................................................... 2-13

Figure 2.1-7 Drill Pit Drawing.................................................................. 2-17

Figure 2.1-8 Development, Production and Restoration Schedule........... 2-36

Figure 2.1-9 Project Water Balance, Production Only ............................. 2-39

Figure 2.1-10 Project Water Balance, Production with GWS .................... 2-40

Figure 2.1-11 Project Water Balance, Production with GWS and RO ....... 2-41

Figure 2.1-12 Project Water Balance, Production with RO ....................... 2-42

Figure 2.1-13 Project Water Balance, GWS and RO, No Production ........ 2-43

Figure 2.1-14 Project Water Balance, RO, No Production ......................... 2-44

Figure 2.3-1 Photo of the East Access Road ............................................ 2-91

Figure 2.3-2 Photo of the West Access Road ........................................... 2-91

Figure 2.3-3 Alternate Access Road Map ................................................. 2-93

List of Tables 

Table 2.1-1 Waste Streams ...................................................................... 2-25

Table 2.1-2 Project Monitoring ............................................................... 2-47

Table 2.2-1 Cross-References to Environmental Protection Measures and 

Impacts in WDEQ-LQD and NRC 

Documents ......................................................................... 2-53

Table 2.2-2 BLM Required Measures ..................................................... 2-58

Table 2.3-1 Comparative Summary of Impacts ...................................... 2-63
2.0 PROPOSED ACTION AND ALTERNATIVES

2-52 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

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 have 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 

was received and a hearing held before the Wyoming Environmental Quality 

Council. The WDEQ-LQD decision was upheld (Wyoming EQC, 2011). 

The BLM reviewed the permitting and licensing actions, in particular the WDEQLQD Permit to Mine and the NRC License and Supplemental Environmental 

Impact Statement (SEIS), and the required environmental protection measures 

associated with them, for conformance with the Rawlins RMP and performance 

standards of 43 CFR 3809.420 to prevent unnecessary or undue degradation per 

43 CFR 3809.411(d). Table 2.2-1 is a cross-reference, by resource and activity, 

to the sections of the WDEQ-LQD Permit to Mine, NRC License, and SEIS in 

which the required 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. 
2.0 PROPOSED ACTION AND ALTERNATIVES

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-53 

April 2012

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

2-54 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

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

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-55 

April 2012

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

2-56 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

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

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-57 

April 2012

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

2-58 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

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

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

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

required measures and monitoring are discussed first, followed by the impact 

significance criteria and impact assessment. The need for any additional 

mitigation measures is discussed at the end of Section 4.0. 

Based on the BLM’s review and on the comments received during the BLM 

scoping process, additional measures are 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. 

 

Table 2.2-2 BLM Required Measures (Page 1 of 2) 

Resource Aspect BLM Required Measures 

Surface 

Water 

Ephemeral 

Drainages 

Surface disturbing activities would be 

avoided within 100 feet of the inner gorge 

of ephemeral channels. Exceptions to this 

would be granted by the BLM based on an 

environmental analysis and site-specific 

engineering and mitigation plans. Only 

those actions within areas that cannot be 

avoided and that provide protection for the 

resource identified would be approved. 

Groundwater Stability Monitoring To support combined agency review of 

current stability monitoring requirements, 

at least two additional stability monitoring 

samples would be collected, once every 

three months over a six-month period, after 

the initial stability period. 

Wildlife – 

Greater 

sage-grouse 

Seasonal 

Restrictions 

Based on bird behavior within the Rawlins 

Field Office Area, the dates of the seasonal 

restrictions are slightly longer than in other 

areas in Wyoming. Activity (production 

and maintenance activities exempted) 

would be prohibited from March 1st

through July 15th outside of the 0.6 mile 

perimeter of an occupied lek within 

suitable habitat, as compared to the March 

15th through July 1st time frame applicable 

in other areas of Wyoming. 
2.0 PROPOSED ACTION AND ALTERNATIVES

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-59 

April 2012

Table 2.2-2 BLM Required 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 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 perching and collision 

deterrents, with the exception of the 

fencing around the Storage Ponds, which 

would be exclusion fencing. 

Wild Horses Access to Fenced 

Pattern Areas 

To help protect healthy herds of wild 

horses, LCI would work with BLM to 

determine if 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. 

2.3 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 six million pounds of uranium over an operating period of 12 years. 

Several alternatives were identified from BLM review of the Proposed Action and 

from the issues and concerns raised from public scoping comments and 

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 
2.0 PROPOSED ACTION AND ALTERNATIVES

2-60 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

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 On-Site Dryer (also evaluated in the NRC SEIS). 

Alternatives considered but eliminated from detailed study include: 

x Portable Drill Pits; 

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 

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. 
2.0 PROPOSED ACTION AND ALTERNATIVES

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-61 

April 2012

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 is 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 

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 is isolated from the yellowcake so that 

no radioactive materials are entrained in the heating system or its exhaust. The 

drying chamber that contains the yellowcake slurry is under vacuum, so that any 

potential leak would cause air to flow into the chamber rather than out. Drying 

takes place at relatively low temperatures. Emissions from the drying chamber 

are normally treated through a bag filter to remove yellowcake particulates; and 

any water vapor exiting the drying chamber is cooled and condensed. 

The dried product (yellowcake) is 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 also 

has a bag filter dust collection system to protect personnel and to minimize 

yellowcake release. Air from the bag filter dust collection system is typically 

routed to the dryer off-gas line and scrubber. During drum loading, the drum is 

also kept under negative pressure via a drum hood with a suction line. The final, 

dried product is 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. The Applicant notified 

NRC in April 2011 that they intend to request an amendment to their NRC 

License to install a rotary vacuum dryer, and the application was submitted to 

NRC in January 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 
2.0 PROPOSED ACTION AND ALTERNATIVES

2-62 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

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. 
April 2012

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-63 

Table 2.3-1 Comparative Summary of Impacts (Page 1 of 14) 
2-64 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

Table 2.3-1 Comparative Summary of Impacts (Page 2 of 14) 
April 2012

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-65 Table 2.3-1 Comparative Summary of Impacts (Page 3 of 14) 
2-66 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

Table 2.3-1 Comparative Summary of Impacts (Page 4 of 14) 
April 2012

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-67 

Table 2.3-1 Comparative Summary of Impacts (Page 5 of 14) 
2-68 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

Table 2.3-1 Comparative Summary of Impacts (Page 6 of 14) 
April 2012

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-69 

Table 2.3-1 Comparative Summary of Impacts (Page 7 of 14) 
2-70 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

Table 2.3-1 Comparative Summary of Impacts (Page 8 of 14) 
April 2012

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-71 

Table 2.3-1 Comparative Summary of Impacts (Page 9 of 14) 
2-72 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

Table 2.3-1 Comparative Summary of Impacts (Page 10 of 14) 
April 2012

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-73 

Table 2.3-1 Comparative Summary of Impacts (Page 11 of 14) 
2-74 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

Table 2.3-1 Comparative Summary of Impacts (Page 12 of 14) 
April 2012

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-75 

Table 2.3-1 Comparative Summary of Impacts (Page 13 of 14) 
2-76 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

Table 2.3-1 Comparative Summary of Impacts (Page 14 of 14) 
2.0 PROPOSED ACTION AND ALTERNATIVES

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-77 

April 2012

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 three 

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 
2.0 PROPOSED ACTION AND ALTERNATIVES

2-78 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

(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 

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 reestablishment, 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). BLM and WDEQ-LQD site 

inspections, 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. 
2.0 PROPOSED ACTION AND ALTERNATIVES

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-79 

April 2012

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 

would be needed at that location for the life of the Project. Therefore, using the 

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

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

Several concerns were also identified with respect to Project-wide use of portable 

mud pits. The first and second concerns for using portable mud pits relate to 

transportation and wildlife, respectively. The third relates to 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 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 
2.0 PROPOSED ACTION AND ALTERNATIVES

2-80 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

considered more problematic than 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 

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. 

Open Pit Mining 

Open pit mining requires the removal of all material covering the orebody 

(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 use). 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 orebody 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 
2.0 PROPOSED ACTION AND ALTERNATIVES

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-81 

April 2012

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. 

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. 

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 orebodies, horizontally driving crosscuts 

and drifts to the orebodies 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 are being 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 is 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) 

material. The Project would generate about 105 gallons of liquid process waste 
2.0 PROPOSED ACTION AND ALTERNATIVES

2-82 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

per minute, primarily from the production and eluate bleeds and the yellowcake 

wash water. The production bleed would generate approximately 100 gpm. An 

additional 5 gpm would be generated from the eluate bleed and yellowcake wash 

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 is 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 they 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 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 (2008). 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 is 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, evaporation ponds would be frozen and 
2.0 PROPOSED ACTION AND ALTERNATIVES

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-83 

April 2012

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

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

are radioactive and extensive efforts are needed during the reclamation phase to 

clean up and dispose of these solid wastes. Sludge accumulation could also 

decrease the useful life of the pond. 

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 

National Emissions Standards for Hazardous Air Pollutants (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 permit limits. 

As with the evaporation pond alternative, severe winter conditions in the Permit 

Area would limit the efficiency of land application. Storage of the water would 

be necessary during winter months. This would require an additional storage 

pond to hold the treated water during 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 are 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’. 
2.0 PROPOSED ACTION AND ALTERNATIVES

2-84 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

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 

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. 
2.0 PROPOSED ACTION AND ALTERNATIVES

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-85 

April 2012

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

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

annually, LCI would review and revise the schedule and WDEQ-LQD Permit to 

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

reported to WDEQ, NRC, and BLM in LCI’s Annual Report. 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, 

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 Memorandum of 

Understanding between BLM and 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 reestablishment criteria. 

To meet groundwater concentration and/or vegetation reestablishment 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 reestablishment criteria as the basis for the phases) would not be 

economically efficient 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 
2.0 PROPOSED ACTION AND ALTERNATIVES

2-86 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

reclamation is required, but not complete closure of one mine pit before starting 

another. In addition, this alternative would result in idling of the Plant for some 

periods of time, which would require additional expense and resources (e.g., resin 

replacement) for temporarily ‘mothballing’ and then restarting the Plant. With 

respect to technical options, re-use of water from one mine unit, after it goes 

through the Plant, in another mine unit would not be available, resulting in 

additional groundwater consumption (e.g., Groundwater Transfer, Section RP 

2.3.2 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). 

In essence, the schedule-based approach in the Proposed Action includes the 

specific restoration and reclamation parameters along with how they would be 

evaluated (e.g., Section 6.1.3 of the Mine Unit 1 [LCI, 2011b]) and allows 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. 

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 formations 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 premining 

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 
2.0 PROPOSED ACTION AND ALTERNATIVES

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-87 

April 2012

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 in 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 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 

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. 
2.0 PROPOSED ACTION AND ALTERNATIVES

2-88 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

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. 

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 WDEQ, the northern location was 

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

further consideration (LCI, 2008, 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, 

State, BLM, and NRC, including: 

x For emergency purposes, Sweetwater County requires two access roads 

for ingress and egress (LCI, 2011a). 

x 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. 
2.0 PROPOSED ACTION AND ALTERNATIVES

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-89 

April 2012

x 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 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 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, 

WDEQ-LQD, 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 the number and type of 

vehicles, and materials transported, including equipment, supplies, wastes, and 

products. WDEQ-LQD reviewed LCI’s Permit to Mine for compliance with State 

environmental requirements (LCI, 2011b), and WGFD analyzed the WDEQ-LQD 

Permit to Mine (LCI, 2011b) for compliance with the Wyoming Sage Grouse 

Executive Order 2011-5 (SGEO) 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 Sooner Road to the east Permit 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 Wamsutter-Crooks Gap Road to the west 

Permit 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 Wamsutter-Crooks Gap Road south to I-80. In the Proposed Action, 
2.0 PROPOSED ACTION AND ALTERNATIVES

2-90 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

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 Executive Order No. 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 

Order does allow for exceptions to be considered on a case-by-case basis (Mead, 

2011). 

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, 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 sagegrouse 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. 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. 
2.0 PROPOSED ACTION AND ALTERNATIVES

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-91 

April 2012

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
2.0 PROPOSED ACTION AND ALTERNATIVES

2-92 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

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 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 off of 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 twotrack road and the construction of three to four miles of new road. This option 

avoids the 1-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. 

The option for the Southern Alternate Access Road, off of 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 nests; however, both new and existing roads 

associated with this alternative are still entirely within the Greater sage-grouse 

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. 
April 2012

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 2-93 
2.0 PROPOSED ACTION AND ALTERNATIVES

2-94 DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

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 

Resource Management Plan (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 road and 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. WGFD determined that construction of new 

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

than the improvements made to 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. 

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

proposed East and West Access Roads to be in compliance with Executive Order 

No. 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 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.