2.0 PROPOSED ACTION AND ALTERNATIVES

2.1.2.3 Mine Units 

Mining would progress along the ore trend through a series of mine units. The 

specific number of mine units and boundaries of each mine unit are considered 

conceptual until a more detailed ‘mine unit package’ is prepared for that mine unit 

and submitted to WDEQ-LQD. 

The layout of each mine unit consists of production and injection wells in a 

pattern area surrounded by a monitor well ring. The layout of wells in a typical 

mine unit are shown on Figure 2.1-4. There are four types of monitor wells: 

those completed in the monitor ring around the production zone; those completed 

in aquifers directly overlying and underlying the production zone; and those 

completed within the pattern areas. A fifth type of monitor well, a trend well, 

may be used in specific circumstances to provide more detailed information in a 

localized area. Prior to mine unit production, monitor wells are drilled and 

installed to provide information about subsurface conditions. During mine unit 

operation, water quality samples from the monitor wells are collected and 

analyzed to detect an excursion or, if screened in the production zone, to provide 

information on the mining process. The wells in the monitor ring would be 

spaced about 500 feet apart, depending on the hydrogeology of the production 

zone, and would be located approximately 500 feet outside the pattern area. 

Monitor wells in the overlying and underlying aquifers are generally uniformly 

distributed across the pattern area, with approximately one overlying and one 

underlying well every four acres of the pattern area. Similarly, monitor wells in 

the production zone are generally uniformly distributed across the pattern area, 

with one well every four acres of the pattern area. Specific criteria for the 

monitor wells depend on the mine unit characteristics (e.g., see the WDEQ-LQD 

Mine Unit 1 documents [LCI, 2011b]). 

The surface facilities in a typical mine unit are shown on Figure 2.1-5. Each

production and injection well is connected to a manifold in a building commonly 

called a header house. Each header house accommodates the well controls and 

distribution plumbing for approximately twenty production wells and the 

associated injection wells (usually about 40 injection wells). The manifolds route 

solutions in pipelines to and from the ion exchange circuit in the Plant. Other 

mine unit facilities on or just below the surface include roads, pipelines, and 

transmission lines. Topsoil stockpiles are also present for storage of topsoil 

removed from areas that would be disturbed for the life of the mine unit, e.g., 

underneath header houses. The surface disturbance in each mine unit was 

estimated for the WDEQ-LQD Permit to Mine, and the estimates are refined, if 

necessary, in each mine unit package. 

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2.1.2.4 UIC Class I Wells 

On May 28, 2010, LCI obtained the UIC Class I Permit No. 09-586 from WDEQWQD, which has primacy in Wyoming for the UIC program. The permit 

authorizes LCI to drill, complete and operate up to five wells for waste water 

disposal at depths between 6,139 and 9,590 feet below the ground surface and 

according to procedures and conditions of UIC Class I Permit Application No. 09-

586 (Attachment ADJ-2 of the Adjudication Files in the WDEQ-LQD Permit to 

Mine [LCI, 2011b]) and to the requirements and other conditions of UIC Class I

Permit No. 09-586, in compliance with the Wyoming Environmental Quality Act 

(Wyoming Statute (WS) §§ 35-11-101 through 1104, specifically 301(a)(i) 

through 301 (a)(iv), Laws 1973, Ch. 250, Section 1) and Wyoming Water Quality 

Rules and Regulations Chapter 13. Not all of these wells may be needed and not 

all of them would be installed initially. The wells are planned as the primary 

disposal method for the liquid 11(e)(2) byproduct materials, which are defined in 

Section 11(e)(2) of the Atomic Energy Act as tailings or wastes produced by the 

extraction or concentration of uranium or thorium from any ore processed 

primarily for its source material content. The 11(e)(2) byproduct material is 

regulated by the NRC under Title 10 CFR Part 40. In addition to the liquid 

11(e)(2) byproduct materials, other compatible liquid wastes would be disposed 

of in the wells. The wells would be monitored in accordance with the 

requirements of the UIC permit; and an evaluation of the well performance would 

be included in the Annual Report submitted to the WDEQ, the NRC, and the 

BLM. 

A deep well in the southwest corner of the Permit Area (Figure 1.2-2) was 

installed in November and December 2008 and tested in February 2009 (under a 

WDEQ-LQD mineral exploration permit) to obtain necessary subsurface 

information on the feasibility of this disposal option. As noted in Attachment 

ADJ-2 of the Adjudication Files in the WDEQ-LQD Permit to Mine, the waters in 

the proposed injection zone (between 6,100 and 10,000 feet below the surface) 

and all waters below the injection zone qualify for WDEQ classification as Class 

VI groundwater (LCI, 2011b). The laboratory results of water quality samples 

collected from the proposed injection zone indicated poor water quality: total 

dissolved solids concentrations in excess of 10,000 milligrams per liter; 

exceedances of groundwater quality standards for organic constituents (benzene, 

ethylbenzene, and oil and grease); exceedances of groundwater quality standards 

for inorganic constituents (mercury, manganese, barium, lead, arsenic, and iron); 

and exceedances of groundwater quality standards for radionuclides (gross alpha 

particle activity and combined radium 226+228). Hence, the formations below 

the proposed injection zone are not underground sources of drinking water. Thus, 

the proposed wells are Class I injectors, as defined in federal and state UIC 

regulations (40 CFR Part 144 and WDEQ Chapter XIII, respectively). Upper 

level confinement would be provided by about a 300-foot-thick shale sequence in 

the basal Wasatch/Battle Spring and injection would be confined below by the 

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2.0 PROPOSED ACTION AND ALTERNATIVES

low-permeability shales of the Upper Lance Formation. The locations of the five 

UIC Class I wells (Figure 1.2-2) are widely scattered to accommodate regulatory 

requirements and meet the necessary injection criteria in compliance with the 

Wyoming Environmental Quality Act (WS §§ 35-11-101 through 1104, 

specifically 301(a)(i) through 301 (a)(iv), Laws 1973, Ch. 250, Section 1) and 

Wyoming Water Quality Rules and Regulations, Chapter 13. 

2.1.2.5 Roads 

Roads in the Permit Area are defined as primary, secondary, or tertiary per 

WDEQ-LQD Guideline No. 4 (2000a) Attachment III, Section III(B) based on 

their dimensions, construction, and frequency of use. Wherever possible, roads 

would follow existing two-track routes to minimize additional disturbance. Roads 

would be constructed or improved in accordance with BLM guidance found in 

“Engineering: Road Standards: Excerpts from BLM Manual, Section 9113” 

(BLM, 1996a). Figure 2.1-6 illustrates general road designs based on BLM 

guidance. 

The primary access roads, the East and West Access Roads, would extend from 

the Sooner Road and the Wamsutter-Crooks Gap Road, respectively, to the Plant. 

These roads would be upgraded immediately prior to the Plant’s construction. 

Secondary access roads and associated culverts for the UIC Class I wells would 

be constructed prior to the installation of those wells. The secondary access roads 

and associated culverts for each mine unit would be constructed prior to and 

during the installation of each mine unit. These roads would connect the header 

houses within a mine unit and connect each mine unit to the Plant. Specific 

locations of the secondary roads would be included with each mine unit package, 

when their precise locations are known. There would also be two-track (tertiary) 

access roads within the mine units during field construction and operation to 

access header houses and monitor wells. These two-track roads would not be 

improved roads because of the limited traffic on them. However, with WDEQLQD concurrence, specific travel routes would be designated within the mine 

units to reduce the potential for topsoil compaction and erosion. 

New roads or upgrades to existing roads may require the establishment of an 

ephemeral drainage crossing. Ephemeral drainage crossings may be constructed 

using either culvert installation or establishment of a ford, and in either case, to 

the degree possible, would be oriented perpendicular to the channel. LCI may 

elect to construct fords in cases where the ephemeral drainage channel is 

relatively shallow, on the order of three feet deep or less. Where fords are 

established, each entrance would be graded to a slope of 5(horizontal):1(vertical) 

or less and the base would be lined with gravel and cobbles to assure traction. 

Once final road design were developed, the BLM would evaluate each ephemeral 

drainage crossing to ensure proper plans were developed for the site-specific 

conditions. 

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Culvert design criteria are based on WDEQ-LQD Guideline No. 8 (2005a) that 

factors in the design life of the Project along with the hydrologic return period or 

flood frequency probability. Culvert design for the primary access roads would 

be based on the estimated peak flow from the 25-year, six-hour storm event; and 

the designs for the secondary roads would be based on the estimated peak flow 

from the ten-year, six-hour storm event. Per “Engineering: Road Standards: 

Excerpts from BLM Manual, Section 9113,” no culvert smaller than 18 inches in 

diameter would be used (BLM, 1996a). To minimize erosion potential at the 

culvert outlets, rock riprap aprons would be installed where appropriate. 

2.1.2.6 Fences

The Plant, including the Storage Ponds, would be fenced for the duration of the 

Project. Pattern areas in the mine units (excluding the monitor ring) would also 

be fenced as they are constructed and brought on-line. Exploration drilling mud 

pits located outside of the fenced portion of the mine units would also be 

temporarily fenced. All fences would be constructed according to BLM fencing 

specifications and WGFD criteria. 

The fence around the Plant would enclose ten acres. Eight acres of the Plant 

would have standard wildlife-friendly fencing based on BLM Manual Handbook 

1741-1, Fencing (1989), which would keep cattle and wild horses out but would 

allow the passage of pronghorn and other wildlife. The fence around the Storage 

Ponds (enclosing two acres) would be constructed to prevent access by wildlife,

cattle, and wild horses for safety reasons (Type II fencing per WDEQ-LQD 

Guideline No. 10 [1994c]). 

Because the mine units are mined in succession, not all the pattern areas would 

necessarily be fenced at the same time. However, if all of the proposed 

disturbance areas of the Project were fenced at once, 345 acres (eight percent) of 

the 4,254-acre Permit Area would be removed from livestock grazing. Pattern 

area fences would be standard wildlife-friendly fencing based on BLM Manual 

Handbook 1741-1, Fencing (1989), which would keep cattle and wild horses out 

but would allow the passage of pronghorn and other wildlife. The fences would 

be removed after ISR operations are complete and vegetation has become reestablished in accordance with permit requirements as described in Section RP 

4.5.4 of the WDEQ-LQD Permit to Mine Reclamation Plan (LCI, 2011b) unless 

otherwise approved and agreed upon with the landowner (BLM). 

Access to the fenced areas would be through gates (e.g., at the Storage Ponds) or 

pitless cattle guards (e.g., at the pattern areas). Because there is the potential for 

gates to be inadvertently left open on occasion, pitless cattle guards may be used 

in conjunction with gates to prevent cattle and wild horses from entering an open 

gate and becoming trapped in the fenced area. 

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2.1.3 Construction 

The Construction phase includes both the initial construction of the Plant and 

other life-of-mine facilities and the progressive development of mine units during 

the Project. 

2.1.3.1 Initial Construction 

Standard construction techniques for industrial facilities would be used for 

construction of the Plant, Storage Ponds, and associated facilities. The 

construction would involve the use of heavy equipment, such as bulldozers, 

excavators, and cranes, to excavate footings, erect buildings, build the ponds, and 

place tanks and other large containers. Supplies and specialized equipment would 

generally be delivered by tractor-trailers, with some equipment being delivered by 

rail and then tractor-trailers, or delivered by smaller trucks or vans. 

Graders, bulldozers, rollers, and similar equipment would be used for road 

upgrades. Specifications for the facilities and roads are included in the WDEQLQD Permit to Mine and the NRC Material License (LCI, 2010 and 2011b). 

Construction and testing requirements for the UIC Class I wells are included in 

Sections G and L of the WDEQ-WQD UIC Permit, which is included in 

Attachment ADJ-2 of the WDEQ-LQD Permit to Mine (LCI, 2011b). Drilling 

would be conducted by a carrier-mounted rotary drill rig (similar to ones typically 

used for oil and gas drilling) with accompanying generators, mud systems, pipe 

racks, logging trucks and personnel vehicles. For the purpose of calculating 

surface disturbance for the Project, it was assumed that a three-acre drilling pad 

would be needed for drilling each deep well and that, upon drilling completion, a 

well house (cumulatively requiring less than 0.2 acres, including the pull-out 

drive) would be constructed and the remaining 2.8 acres of the drilling pad would 

be reclaimed. 

2.1.3.2 Mine Unit Development 

The activities during development of each mine unit are similar, with the unitspecific details included in the Hydrologic Test Proposal and subsequent Test 

Report submitted to WDEQ-LQD for review and approval prior to the 

construction of each mine unit. 

Drilling 

Exploration, delineation and well drilling would be conducted by truck-mounted 

water well-type rotary drill rigs with accompanying water trucks, pipe trucks, 

logging trucks and personnel vehicles. Due to the low relief of the Permit Area 

and the use of a drilling rig with hydraulic leveling jacks, little or no leveling or 

alteration of surface topography would be required during drilling operations. 

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While digging mud pits, constructing drill pads, or any other excavation, topsoil 

would be preserved using the techniques required by the WDEQ-LQD Permit to

Mine (e.g., Section OP 2.5, LCI, 2011b). Disturbance areas would be reclaimed 

as soon as possible in order to minimize the total amount of land disturbed at any 

given time in accordance with WDEQ-LQD and BLM policies. 

Because of the limited amount of traffic, and small size of equipment needed to 

drill units within the mine, no developed roads would be constructed. Traffic 

routes would be delineated by stakes to reduce overall potential for multiple 

routes being developed within each mine unit. 

Drill rigs would use native groundwater supplied from wells within the Permit 

Area. Drilling fluids may consist of bentonite-based muds, polymers, inert lost 

circulation material, and minor amounts of soda ash to soften drill water. No 

hazardous chemicals would be used during drilling. Drilling locations would be 

modified, where possible, to avoid drilling in major drainage ways and/or major 

modifications to the terrain. 

To avoid degradation of topsoil adjacent to mud pits, the pits would be installed 

so, at a minimum, the primary root zone topsoil (generally the top four to eight 

inches) would be removed and stockpiled separate from the stockpile of the 

subsoil excavated for the mud pit. One mud pit would be used at nested well 

locations, if possible. After drilling, the mud pit would be allowed to dry and then 

the subsoil would be replaced, followed by the replacement of topsoil, which 

would be redistributed as evenly as practical over the excavation area. Finally, 

the surface would be prepared and reseeded with the permanent seed mix at the 

next appropriate season, or, if necessary to prevent erosion prior to the next 

appropriate season, with a temporary seed mix (rigorous certified weed-free 

annual cover crop, such as sterile rye grass or millet). Figure 2.1-7 shows the 

typical layout of a drill pit. 

Drill pits would be backfilled with subsoil as soon after drilling as is practical. 

Topsoil would not be re-applied until the subsoil had been given adequate 

opportunity to settle into the pit. All but the UIC Class I well drilling sites would 

be in use for only a few days. The UIC Class I well drilling sites may be in use 

for several weeks or a few months. 

Well Construction and Casing Integrity 

The injection, production, and monitor wells would be drilled, logged, and cased 

in accordance with the requirements described in Section OP 3.3 of the WDEQLQD Permit to Mine (LCI, 2011b). Additional details on well integrity testing 

procedures are included in Section OP 3.4 of the WDEQ-LQD Permit to Mine 

(LCI, 2011b). 

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Pump Testing and Water Quality Sampling 

For each mine unit, the monitor well ring and monitor wells in the proposed 

pattern area and overlying and underlying aquifers would be installed first. A 

multi-day pump test would then be conducted to ensure that the monitor ring 

spacing is sufficient to detect any excursions from the pattern area. The pump test 

would also be used to ensure adequate separation between the production zone 

and the overlying and underlying aquifers and whether any trend wells would be 

needed at locations where unanticipated conditions might occur. 

Once pump testing was complete, the monitor wells would be sampled to 

establish baseline water quality and excursion parameters and limits (commonly 

referred to as Upper Control Limits). The monitoring would be conducted at 

specified intervals, as described in Section OP 3.6.4 of the WDEQ-LQD Permit to 

Mine (LCI, 2011b). 

Surface Facilities 

The layout of each mine unit, including roads, pipelines, power lines, and header 

houses, would be designated in the Hydrologic Test Report submitted to WDEQLQD. The construction equipment for the surface facilities in the mine units is 

relatively small in comparison to the equipment needed for the Plant. Small 

dozers and graders would be used for road improvements, as necessary. If 

possible, a ‘ditch witch’ would be used for pipeline installation, or a small 

backhoe may be needed in some locations. Truck-mounted cranes may be used to 

place header houses assembled elsewhere on-site (e.g., at the Plant) or the header 

houses may be assembled on location. Pumps would be set with truck-mounted 

equipment. 

To minimize erosion potential, weed invasion, and related problems, the mine unit 

reclamation activities would commence immediately upon construction 

completion. Vegetative cover would be maintained during the mine unit 

operation through monitoring and additional seeding when necessary. 

An essential activity that would occur throughout the life of the Project is 

monitoring of all aspects of the system, including operational and environmental 

parameters, by qualified personnel and review of the data to ensure the results are 

as anticipated. Section 2.1.7 provides a general overview of monitoring related to 

the Project. 

2.1.4 Operation (Production) 

2.1.4.1 Mine Units 

Mine units are generally developed and activated in stages. Commonly, new 

production is started by header house, rather than by a complete new mine unit. 

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Depending on available pipeline and Plant capacity, an operator may initiate new 

production in areas as discrete as individual patterns. 

The uranium ISR process starts at the mine units by introducing lixiviant into the 

ore zone through the injection wells. The lixiviant is composed of native 

groundwater, carbon dioxide and oxygen or an equivalent oxidizing agent. 

Carbon dioxide may be added at the Plant, based on the pH adjustment needs. 

Oxygen would be added to the barren lixiviant at the mine unit header houses. 

When the lixiviant is injected into the ore zone, the dissolved oxidant reacts with 

+6 the uranium mineral and brings the uranium to the U oxidation state. The 

uranium then complexes with some of the carbonates in the lixiviant to form a 

-2 uranyl dicarbonate ion [UO2(CO3)2] and/or a uranyl tricarbonate ion 

-4 [UO2(CO3)3] , both of which are soluble and stable in solution. A small portion 

of the radium content would also be mobilized along with the uranium. 

Depending on the site conditions, other metals, such as arsenic, molybdenum,

selenium, and/or vanadium, may also be mobilized. The resultant uraniumbearing solution would be recovered from the production wells to the surface. 

The injection and production rates would be balanced to control the movement of 

fluids in the aquifer. Section OP 3.6 and Attachment OP-2 of the WDEQ-LQD 

Permit to Mine describe the mine unit control procedures in detail (LCI, 2011b). 

In each mine unit, more uranium-bearing solution would be extracted than 

lixiviant injected, which creates a localized hydrological cone of depression or 

pressure sink. The anticipated overproduction or bleed would be a nominal 0.5 

percent to one percent of the production rate. Under this pressure gradient, the 

groundwater in the surrounding area would move toward the mine unit, 

minimizing the possibility of an excursion. 

2.1.4.2 Plant 

The ion exchange circuit at the Plant receives the uranium-bearing solution from 

the mine unit(s) through buried pipelines. The Plant is designed for a flow rate of 

6,000 gallons per minute (gpm), and the balance of production and restoration 

capacities is described in detail in Section OP 3.6.3.1 of the WDEQ-LQD Permit 

to Mine (LCI, 2011b). Several processes occur in the Plant, many of which 

involve waste disposal, which is discussed in Section 2.1.4.4. Effluent control 

systems (including gaseous emissions, liquid wastes, and solid wastes) have been 

evaluated by NRC in Sections 4.14 and 5.14 of the SEIS (2011a) and by WDEQLQD in Section 5.0 of the Permit to Mine (LCI, 2011b). The following 

operations, described in more detail in Section OP 4.0 of the WDEQ-LQD Permit 

to Mine (LCI, 2011b) occur inside the Plant: 

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2.0 PROPOSED ACTION AND ALTERNATIVES

Resin Loading 

The dissolved uranium in the pregnant lixiviant from the mine units would 

chemically adsorb onto the ion exchange resin as the lixiviant passes through the 

resin. The barren lixiviant exiting the resin would normally contain less than five 

milligrams per liter of uranium. A slip stream of the barren lixiviant would be 

treated with reverse osmosis (RO) to remove any remaining impurities (e.g., other 

metals) before sending the lixiviant back to the field for re-injection. The bleed 

portion of the fluid would be treated and disposed of via a UIC Class I well. 

Resin Elution 

When resin in an ion exchange vessel is loaded and removing very little 

additional uranium from the incoming solution, the resin would then be 

transferred to an elution vessel. The resin would be contacted with an eluate 

composed of approximately 90 grams per liter (g/L) sodium chloride and 20 g/L 

sodium carbonate (soda ash). The eluted resin would be rinsed with fresh water 

and transported back to the ion exchange facility and placed in an ion exchange 

vessel for additional uranium recovery. The rinse water would be collected, 

treated, and recycled back into the process. 

Precipitation and Filtration

From the elution circuit, the uranium-bearing eluate would be sent to an agitator 

tank for batch precipitation. To initiate the precipitation cycle, hydrochloric or 

sulfuric acid would be added to the eluate to breakdown the uranyl carbonate 

present in the solution. Hydrogen peroxide would then be added to the eluate to 

effect precipitation of the uranium as uranyl peroxide. Caustic soda solution 

would then be added to elevate the pH, which promotes growth of uranyl peroxide 

crystals and makes the slurry safer to handle in the subsequent process steps. 

After precipitation, the precipitated uranium would be washed, to remove excess 

chlorides and other soluble contaminants, and then de-watered and filtered to 

form the yellowcake slurry. This slurry of approximately 40 percent of water 

would then be stored in holding tanks or in transport tanks parked in a secure area 

in the Plant. The holding and transport tanks would be used solely for yellowcake 

slurry. On-site inventory of U3O8 in the slurry form would typically be less than 

100,000 pounds. However, in periods of inclement weather or other interruptions 

to product shipments, there would be a capacity for up to 200,000 pounds of 

slurry within the Plant. The yellowcake slurry would be shipped by exclusiveuse, authorized transport to a facility licensed by NRC for processing the slurry 

into dry yellowcake. A final destination for outgoing shipments of yellowcake 

slurry has not been determined at this time. Transportation associated with the 

Project is discussed in Section 4.3. Transport of the product and waste has 

undergone thorough review by NRC in Section 4.3 of the SEIS (2011a). 

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2.1.4.3 Instrumentation and Control 

For control and monitoring purposes, two separate control systems would be used 

during ISR operations (Sections OP 3.5 and 4.4 of the WDEQ-LQD Permit to 

Mine [LCI, 2011b]). Each system would be designed and instrumented to 

accommodate the steady state or batch flow characteristic of particular process 

flow streams or unit operations. The control systems would employ state-of-theart hardware and software with proven as well as demonstrated process logic. 

Since the mine unit resin loading circuit operates at a steady state, modest 

deviations from the normal operating flow rates and pressure profiles (plus or 

minus ten percent or greater) would be indicative of major operating upsets. An 

automatic Emergency Shut Down (ESD) system, consisting of pressure and flow 

rate switches, would be provided for this circuit. In the event of an automatic 

shutdown, an alarm would notify the operator of the situation. Once the major 

upset (broken piping, leaking vessel, etc.) is identified and corrective action taken, 

only then can the circuit be manually restarted. This type of control system 

provides the best protection against fluid spills to the environment and product 

losses. The back-up for the automatic ESD system is provided by local displays 

of the same flow rates and pressures that the ESD system monitors. Due to spill 

prevention practices in place, including monitoring of changes in pressure and 

flow rate and regular equipment checks, there would be a low risk for severe 

spills. In the case of accidental release of mining or process fluids, LCI would 

use designated equipment to recover as much of the solution as possible. If the 

fluid was radioactive, LCI staff would perform a radiological risk assessment. If 

a more severe spill were to occur, NRC would be informed, as required by 10 

CFR 20 and 10 CFR 40 (LCI, 2010). If any accidental release to the environment 

occurred, LCI would verbally notify the WDEQ-LQD and the BLM. 

Additionally, LCI would submit a written report within one week describing the 

location, nature, and cause of the incident, and summarizing any potential releases 

to the environment, problem solving efforts, and future preventative or mitigative 

measures that could be taken in similar events (LCI, 2011b). 

The elution, precipitation, and product filtering, circuits would operate in a batch 

nature. These circuits are controlled by Programmable Logic Controllers (PLCs), 

which sequence the opening and closing of appropriate valves once the processes 

are manually initiated. In addition, the PLCs would provide closed-loop feedback 

control for the elution and precipitation circuits. All automatic valves would be 

equipped with a manual control override. A local indication of pressures, levels, 

flow rates, and pH would be provided for the complete manual control of these 

circuits if required. 

Process water treatment and disposal circuits would operate under semicontinuous, steady-state conditions, which require control systems that integrate 

components of both steady-state and batch operations. 

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2.1.4.4 Effluent Control Systems 

During the Project, gaseous/airborne, liquid, and solid effluents would be 

produced from the processes associated with ISR operations. All the effluents are 

typical for ISR projects currently operating in Wyoming; and existing 

technologies are amenable to all aspects of effluent control in the Permit Area. 

The effluents and procedures for ensuring appropriate handling and disposal are 

summarized below and described in more detail in Section OP 5.0 of the WDEQLQD Permit to Mine (LCI, 2011b) and Sections 4.0 and 5.0 of the NRC Technical 

Report (LCI, 2010). 

Gaseous Emissions and Airborne Particulates

Non-radioactive and radioactive airborne effluents are anticipated during the 

Project. Non-radioactive airborne effluents would be limited to gaseous 

emissions and fugitive dust. The radioactive airborne effluent would be radon 

gas. 

Non-radioactive gaseous emissions would result from the operation of internalcombustion engines. Exhaust from diesel drilling rigs and other diesel or 

gasoline-fueled vehicles would produce small amounts of carbon monoxide, 

sulfur dioxide, and other internal-combustion engine emissions. Most of the 

airborne particulates would be dust from traffic on unpaved roads and wind 

erosion of disturbed areas, such as during installation of wells at a mine unit. 

Airborne particulates may also include insignificant amounts of salt and soda ash 

releases during deliveries to the Plant, and drilling mud or cement dust during the 

installation of wells at the mine units. Construction activities may also generate 

airborne particulates. Examples of this might be welding fumes or dust from 

grinding on steel. 

Carbon dioxide and oxygen would be used as part of the extraction and 

concentration of uranium during mining; and hydrogen sulfide may be used 

during groundwater restoration after mining. However, use of these gases would 

be controlled to prevent waste and potential adverse safety conditions. Similarly, 

any fumes from the limited use of liquid chemicals, such as hydrochloric or 

sulfuric acid, would be controlled (e.g., laboratory hoods). Pressure venting at the 

mine units and supporting facilities would produce some non-radioactive gaseous 

emissions, such as carbon dioxide, oxygen, and water vapor, but the primary 

effluent of concern from pressure venting would be radon gas. 

Radon would be the radioactive gaseous emission from the mining and ore 

processing, as it is present in the ore body and collected with the lixiviant 

solution. Radon would be released occasionally from the mine unit wells as gas is 

vented from the injection wells. Production wells would be sealed at the surface, 

preventing radon emissions during operations and limiting emissions during 

maintenance work. All of the well releases would be outside of buildings and 

would be directly vented to the atmosphere. Radon would also be released during 

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2.0 PROPOSED ACTION AND ALTERNATIVES

ion exchange resin transfers and subsequent ore processing steps. The UIC Class 

I well pump houses would also be vented. 

Liquid Wastes

The Project would generate several different types of liquid wastes, including 

three classified as 11(e)(2) byproduct materials by the NRC. The descriptions of 

these wastes follow, and Table 2.1-1 summarizes the quantities and disposal 

methods. 

Native Groundwater 

Groundwater would recovered during well installation, sample collection, and 

pump testing prior to mining or from portions of the Permit Area not affected by 

mining. This “native” groundwater has not been exposed to any mining process 

or chemicals and would be discharged to the surface under the provisions of a 

general WYPDES permit, in a manner that mitigates erosion, or reused in drilling. 

Storm Water Runoff

Procedural and engineering controls would be implemented so storm water runoff 

from the area of the Plant would not pose a potential source of pollution. Per the 

requirements of the WYPDES, the applicable permits for runoff control during 

construction and operation of the Plant would be obtained from WDEQ-WQD. 

Domestic Liquid Waste 

Domestic liquid wastes would be disposed of in an approved septic system, which 

would receive waste from restrooms, shower facilities, and miscellaneous sinks 

located within the office. In addition, chemical toilets may be temporarily placed 

in mine units and other drilling areas. The septic system and chemical toilets 

would be maintained by a licensed contractor. 

Waste Petroleum Products and Chemicals 

These wastes would be typical for ISR facilities, and would include items such as 

waste oil and out-of-date reagents, none of which would have been closely 

associated with the processing of 11(e)(2) byproduct materials. LCI would be a 

Conditionally Exempt Small Quantity Generator of hazardous wastes, per EPA 

definition. Waste chemicals not closely associated with the processing of 11(e)(2) 

byproduct material would be dealt with in one of two ways, depending on whether 

or not they were part of laboratory operations. Waste items not immediately 

associated with laboratory operations would be clearly labeled and stored in 

sealed containers above ground in accordance with the requirements of the EPA. 

These wastes would be periodically collected by a commercial business for 

recycling or disposal in a licensed disposal facility. Waste chemicals typically 

FINAL EIS – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT – VOLUME I 2-23

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2.0 PROPOSED ACTION AND ALTERNATIVES

associated with the laboratory and its operations would be captured in the drains 

and/or sumps within the laboratory and would go straight to the Plant’s waste 

tanks for eventual deep well disposal. 

Liquid Process Wastes (11(e)(2) Byproduct Material) 

Ore processing produces three liquid wastes with important volumes, a production 

(or hydrologic) bleed (Section 2.1.4.1), an eluate bleed, and yellowcake wash 

water (Section 2.1.4.2). The volume of production bleed would be between 30 

and 90 gpm, totaling 100 gpm when combined with restoration discharge,

depending on the on-going activities. The combined volume of eluate bleed and 

yellowcake wash water (part of the Plant process water) would be on the order of 

5 gpm. In addition, the laboratory analyses for evaluating uranium content of the 

production fluid and similar operational parameters would generate liquid waste 

on the order of 25 gallons per day. The production bleed, eluate bleed, and 

yellowcake wash water would be collected, treated and the waste discharged to 

the Storage Ponds and UIC Class I well(s). 

During operations, there would also be an occasional need to decontaminate 

equipment with a high-pressure water wash so it can be disposed of, sent to 

another NRC-licensed facility, or released for unrestricted use. The water 

resulting from the decontamination would enter the waste water circuit through a 

sump and would ultimately be disposed of in the UIC Class I well(s). 

Groundwater Generated during Well Development and Sample Collection 

(11(e)(2) Byproduct Material) 

It may be necessary to develop (or redevelop) wells and collect samples of 

groundwater that has been affected by the mining operation to the extent that 

surface discharge of the water is not appropriate. During well development and 

sample collection, this water would be collected and treated; and the waste would 

be discharged to the Storage Ponds and UIC Class I well(s). 

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Table 2.1-1 Waste Streams (Page 1 of 2) 

Class

of Waste

Specific 

Waste Type

Estimated 

Monthly 

Quantity

Storage Method Disposal 

Method

Liquid Waste

Non11(e)(2) 

Byproduct

Native 

groundwater Intermittent None

Surface

discharge 

per 

WYPDES 

requirements 

or reuse

Storm water 

runoff Intermittent None

Domestic sewage 20,000 gallons None

Septic tank 

w/ leach 

field

Waste petroleum 

products

40 to 80 

gallons 1 (1) 1 (1)

11(e)(2) 

Byproduct

Hydrologic Bleed 3,060,000 (2)

Wells with ponds 

(3) available 

Disposal 

Well

RO Brine 6,600,000 (2)

Groundwater 

Sweep 5,300,000 (2)

Plant Process 

Water 440,000 (2)

Hazardous 

Material 

(Petroleum 

products & 

chemicals)

Not associated w/ 

laboratory <1 gallon 2 2

Associated w/ 

laboratory <1 gallon None Disposal Well

Solid Waste

Non11(e)(2) 

Byproduct

Paper 1.7 cubic yards 

3 (yd ) Recycle bins 3

Cardboard 3 4.2 yd Recycle bins 3

Kitchen garbage 3 4.2 yd Trash can with transfer 

to dumpster 4

Sewer sludge 3 0.3 yd

No storage; immediate 

transfer to disposal upon 

collecting

4

Mud/cement 

sacks

3 16.7 yd Dumpster 4

HDPE/PVC 

pipe scrap

3 8.3 yd Dumpster 4

Wooden pallets 3 16.7 yd Stored outdoors 5

Miscellaneous -- Appropriate to material 3
2.0 PROPOSED ACTION AND ALTERNATIVES

2-26 FINAL EIS – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT – VOLUME I 

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Table 2.1-1 Waste Streams (Page 2 of 2)

Class

of Waste

Specific 

Waste Type

Estimated 

Monthly 

Quantity

Storage Method Disposal 

Method

Solid Wastes (cont’d)

11(e)(2) 

Byproduct

Bag filters 3 2.9 yd 6 7

Spent resin 3 0.2 yd 6 7

Tank sludge 3 0.2 yd 6 7

Gloves 3 0.1 yd 6 7

Protective 

coveralls (i.e., 

Tyvek)

3 0.2 yd 6 7

Scale 3 0.1 yd 6 7

Piping 3 2.9 yd 6 7

Valves 3 0.2 yd 6 7

Cardboard 3 0.3 yd 6 7

Paper 3 0.1 yd 6 7

Miscellaneous --- 6 7

Hazardous 

Material

Fluorescent bulbs 2 bulbs

Packaged/

labeled according to 

EPA regulations and 

placed in dumpster

4

Ballast 0.2 ballasts Stored indoors until 

disposal

4

Rechargeable 

batteries 1 pound 3

Miscellaneous --- Appropriate to material 3

(1)

(2)

(3)

1 - Store in sealed, strong, tight, waterproof, labeled container(s) in indoor, bermed, and ventilated area 

adjacent to maintenance shop. Waste petroleum products may be burned on-site to generate heat. If not 

burned on-site, the petroleum waste would be sent to a local permitted recycling facility, such as the 

Casper landfill.

2 - Store in sealed, strong, tight, waterproof, labeled containers above ground in accordance with EPA

requirements and in berms suitable for their contents, e.g., acid waste containers in the acid tank berm.

3 - Recycle to extent possible; remainder of material sent to local licensed landfill.

4 - Send to local permitted landfill or sewage pond as appropriate.

5 - Recycle to extent possible; remainder of pallets sent to local licensed landfill or burned on-site with an 

air quality permit from WDEQ-AQD.

6 - Place in trash container in Plant and then transferred to a Department of Transportation (DOT)-approved 

container for disposal.

7 - Dispose of at a facility licensed by NRC or an Agreement State to receive 11(e)(2) byproduct material 

for disposal. Where possible, equipment would be decontaminated for disposal as non-11(e)(2) 

byproduct material or for re-use.

The processes generating these waste water streams do not always operate concurrently or at full capacity. 

The quantity shown for each waste type (e.g., Hydrologic Bleed) is the maximum.

Generally, 11(e)(2) waste water would be sent directly to a deep well for disposal. However, the option for 

storage in the lined Storage Ponds is available as needed.
2.0 PROPOSED ACTION AND ALTERNATIVES

Groundwater Generated during Aquifer Restoration (11(e)(2) Byproduct Material) 

During the various steps of aquifer restoration, groundwater would be generated; 

and disposal of some or all of the water would be required. During sweep, 

groundwater would be pumped from the production zone, creating an area of 

drawdown. This would create an influx of water from outside the production 

zone that would replace the affected volume of water within the production zone. 

In most cases, the water produced during sweep would be processed for residual 

uranium content through the ion exchange circuit, and then disposed directly to 

the UIC Class I wells. In some cases, the groundwater pumped from the 

production zone may be treated by RO to reduce the waste volume; and the 

treated water (permeate) may be used in Plant processes or for makeup water in 

other restoration activities. To maintain the area of drawdown, the permeate 

would not be re-injected into the production zone, but could be transferred to 

other mine units for use as makeup water or injected into the UIC Class I wells. 

The concentrated byproduct material (brine) would also be injected into the UIC 

Class I wells. 

During RO, groundwater would be pumped from the production zone. The 

pumped water would be treated by RO; and the permeate would be injected back 

into the production zone. To maintain an area of drawdown, an effective bleed 

would occur by adding additional permeate from other RO activities or by adding 

clean water to the permeate at a rate less than the produced rate. The brine from 

the RO treatment would be injected into the UIC Class I wells. Similarly, during 

other restoration steps, the amount of groundwater pumped from the aquifer 

would exceed the amount pumped back to the aquifer; and that excess water 

would be disposed of in the UIC Class I wells. 

Solid Wastes 

Solid wastes, some of which would be classified as NRC 11(e)(2) byproduct 

materials, would be produced during the Project. The descriptions of these wastes 

are presented below, and Table 2.1-1 summarizes the quantities and disposal 

methods. 

Solid Non-11(e)(2) Byproduct Materials 

The solid non-11(e)(2) byproduct materials would include: non-hazardous 

materials typical of office facilities, such as paper, wood products, plastic, steel, 

biodegradable items, and sewage sludge; and hazardous materials also typical of 

office and ISR facilities, such as waste petroleum products and used batteries. 

LCI would be a Conditionally Exempt Small Quantity Generator of hazardous 

wastes, per EPA definition. 

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2.0 PROPOSED ACTION AND ALTERNATIVES

Solid 11(e)(2) Byproduct Materials 

The solid 11(e)(2) byproduct materials would include process wastes, such as 

spent ion exchange resin, filter media, and tank sludge, generated during ISR and 

ore processing, and would include used equipment that becomes contaminated 

during ISR and ore processing. These items include tanks, vessels, personal 

protective equipment (PPE), and process pipe and equipment. Such wastes could 

also include soils contaminated from spills. 

2.1.5 Reclamation 

The Reclamation phase includes both the progressive groundwater restoration and 

surface reclamation of the mine units and the final reclamation of all the life-ofmine facilities, such as the Plant. Reclamation would be in accordance with the 

requirements of the NRC License (2011b), the WDEQ-LQD Permit to Mine 

(2011b), and the BLM Rawlins RMP and associated documents (2008c, 2009b, 

and 2011e).

2.1.5.1 Mine Unit Restoration and Reclamation 

Technical, economic, and operational criteria would be reviewed to determine if 

uranium recovery were complete in a given header house and/or mine unit. When 

the mineral is sufficiently recovered, the lixiviant injection ceases and 

groundwater restoration commences. If a mined unit is adjacent to another unit 

being produced, restoration of a portion of the unit may be deferred to minimize 

interference with the operating unit. However, LCI intends to concurrently 

conduct restoration and mining, e.g., each mine unit would be restored following 

mining (Sections RP 1.0 and 2.0 of the WDEQ-LQD Permit [LCI, 2011b]). 

The aquifer restoration program would use a combination of three primary 

techniques including: groundwater sweep; RO treatment with permeate injection; 

and recirculation. During groundwater sweep, water would be pumped from the 

mine unit without offsetting with water injection. This pumping would create an 

influx of baseline-quality native groundwater into the unit, thereby flushing 

contaminants from areas affected by the horizontal and vertical spreading (flare) 

of the lixiviant during mining. Following sweep, RO would be used to treat water 

pumped from the mine unit, and the treated water would be re-injected into the 

mine unit to reduce contaminant concentrations. After RO, recirculation would 

be initiated. During recirculation, water would be pumped from the mine unit and 

re-injected to homogenize the overall groundwater conditions. Other techniques 

that may be used include groundwater transfer (moving groundwater between a 

mine unit in restoration and another mine unit in operation), addition of a 

reductant (to reduce metal solubility), and biorestoration (to reduce specific

parameters). The same equipment used for production from a mine unit would 

also be used for restoration, with the possible addition of one or two trailers 

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2.0 PROPOSED ACTION AND ALTERNATIVES

housing RO treatment equipment (Section RP 2.3 of the WDEQ-LQD Permit to 

Mine [LCI, 2011b]). 

The goal of groundwater restoration would be to return the water quality 

parameters to the pre-operational class of use as defined by WDEQ-WQD and to 

the requirements of 10 CFR Part 40, Appendix A, Criterion 5B(5) (Section RP 2.2 

of the WDEQ-LQD Permit [LCI, 2011b] and Section 6.1.3.1 of the NRC SER 

[NRC, 2011c]). After completion of groundwater restoration, which would be 

approved by the WDEQ and the NRC, all cased wells would be permanently 

plugged and capped. The well casings would be cut off below plow depth and the 

sites revegetated. Well abandonment would be conducted either with truckmounted rigs, similar to those used for well construction, or hose reels and pulling 

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

As noted in Section 2.1.3, to minimize erosion potential, weed invasion, and 

related problems, surface reclamation in a mine unit would begin immediately 

upon construction completion, and vegetative cover would be maintained during 

mine unit operation. However, after completion of groundwater restoration in a 

mine unit, the subsequent well abandonment, pipeline removal, and demolition of 

surface facilities would result in surface re-disturbance within the mine unit, 

which would need to be reclaimed. Prior to the commencement of this postmining surface reclamation, affected areas and buildings (i.e., header houses) 

would be surveyed and decontaminated, and facilities and ancillary equipment 

would be decommissioned and removed in accordance with NRC requirements. 

Equipment used for decommissioning and removal would be similar to that used 

for construction. 

Prior to revegetation of the mine unit, a tractor may be needed for surface 

preparation of compacted areas, such as two-track roads, and a small backhoe and 

grader for topsoil replacement. Vegetation would be re-established with the 

approved seed mix, which would adequately support the post-operational land 

uses, and was approved by the BLM Rawlins Office on January 14, 2010, and 

WDEQ-LQD (Section RP 4.5.4 of the WDEQ-LQD Permit [LCI, 2011b]). If any 

of the approved seed were unavailable or prohibitive in cost at the time of 

seeding, other locally adapted and certified seed would be substituted with prior 

approval of the BLM and the WDEQ-LQD. On occasion, soil may be stabilized 

by planting a vigorous annual cover crop of rhizomatous species as directed in 

WDEQ-LQD Guideline No. 2 (1997), in which case, LCI would seek and receive 

approval from the BLM and the WDEQ-LQD before planting such species. 

Specific requirements for surface reclamation are included in Sections OP 3.0 and 

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

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2.0 PROPOSED ACTION AND ALTERNATIVES

2.1.5.2 Final Reclamation 

The facilities that would require reclamation and decommissioning include: 

x processing and water treatment equipment, which includes tanks, filters, 

ion-exchange columns, pipes, pumps, and related equipment; 

x buildings and structures, parking areas, processing facilities, shipping 

areas, laydown areas, and offices; 

x waste storage, treatment, and disposal facilities, including the UIC Class I 

wells and the Storage Ponds; 

x buried pipes; 

x topsoil and subsoil stockpile locations; 

x engineering control structures, such as dams and culverts; and 

x roads. 

Final reclamation and decommissioning would begin following any radiation 

surveys and/or soil or equipment remediation required by the NRC. 

With the exception of any facilities, including roads, approved for postoperational use, all of the facilities associated with the Project would be removed 

once uranium processing and groundwater restoration were complete. (Approval 

for post-operational use must be supported by the landowners and/or lessees 

request, and approval from the BLM, which is the surface management agency of 

the Permit Area, and the WDEQ-LQD. If any facility, including a road, remained 

post-operation, the responsibility for long-term maintenance and ultimate 

reclamation of the facility or road would be transferred to the accepting party.) 

Over a period of six months, the Plant and support facilities would be 

radiologically decontaminated, decommissioned, dismantled, and removed. In 

addition, during the same six-month period, surface preparation and reseeding 

would be completed. 

Removal and Disposal of Facilities and Equipment 

Prior to removal and disposal, facilities and equipment would be decontaminated, 

if necessary, in accordance with NRC requirements. Radiologically contaminated 

materials would be disposed of at an NRC-licensed facility; and materials 

contaminated with other industrial constituents would be disposed of at an 

appropriately licensed facility. Decontaminated and non-contaminated materials 

would be removed for salvage or disposed of at an appropriately licensed solid 

waste facility. Equipment used for decommissioning and removal would be 

similar to that used for construction. 

Structures would be decontaminated, if necessary, and moved to a new location, 

salvaged, or dismantled and disposed at an appropriately licensed solid waste 

facility. Concrete flooring, foundations, and foundation materials would be 

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2.0 PROPOSED ACTION AND ALTERNATIVES

decontaminated, if necessary, broken up, and disposed of at an appropriately 

licensed facility. Soil would be replaced at sites from which structures were 

removed in accordance with the depths and acreages salvaged prior to installation 

of the structures. 

Waste Storage, Treatment, and Disposal Facilities 

Those facilities for which a separate license is obtained, e.g., a UIC Class I well 

for waste water disposal, would be transferred to another owner or operator in 

accordance with applicable requirements or reclaimed and decommissioned in 

accordance with the separate license requirements. 

Any contaminated sludge accumulation in the Storage Ponds, the pond liner, and, 

if necessary, the leak detection equipment would be removed, in accordance with 

the standard operating procedure for handling of contaminated materials, and 

disposed of at an NRC-licensed facility. The soil underneath the Storage Ponds 

would be surveyed for radiological contamination, and any areas in which 

concentrations exceed limits for unrestricted use would be excavated and the 

contaminated material disposed of at an NRC-licensed facility. Confirmation 

surveying and sampling would be conducted in accordance with applicable 

requirements to ensure all contaminated material would be removed. 

Buried Piping and Engineering Control Structures 

Buried piping and engineering control structures would be decontaminated and 

removed. 

Roads 

Improved or constructed roads would be reclaimed by removal of culverts, 

removal of road surfacing and road bed materials, and recontouring, as necessary. 

Unimproved roads would be recontoured, if necessary, and scarified, ripped, or 

disced to reduce compaction. 

Soil Replacement and Revegetation 

Areas in which reclamation would be required within the Permit Area include the 

mine units, in particular, where the header houses and roads would be removed, 

and the Plant area. Disturbed areas would be reclaimed to the approved postoperations land uses by regrading the surface to the approximate pre-operations 

contour, re-establishing drainages, replacing salvaged soil, and revegetating the 

areas in accordance with the procedures outlined below. 

During site reclamation, the storm water discharge permits applicable per the 

WYPDES would be maintained. The associated SWPPP would be designed and 

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2.0 PROPOSED ACTION AND ALTERNATIVES

implemented as part of LCI’s compliance with applicable WDEQ-WQD rules and 

would be kept in an accessible location of the Permit Area. 

Post-Operational Land Use 

The post-operational land uses of the Permit Area would be livestock grazing and 

wildlife habitat. Buildings, roads, wells, or other facilities constructed as part of 

the Project would be removed and the disturbance reclaimed, unless prior 

approval was obtained from the landowner (BLM) and the WDEQ to leave the 

facilities in place to improve post-operational access or land use. 

Surface Preparation 

The small areas of disturbance that may be necessary (e.g., due to culvert 

removal) would be graded to approximate pre-operational contours and drainage 

patterns. To avoid creating ruts or other surface damage, loss of soil resources, 

and/or equipment damage, seed bed preparation would be performed under 

appropriate soil conditions (e.g., not when the ground is wet, frozen, or 

exceptionally dry) and climatic conditions (e.g., not during significant 

precipitation events or if the wind is excessive). 

In areas where soil was not removed but was compacted due to site operations, 

e.g., two-track roads used to access monitor wells, soils would be scarified, 

ripped, or disced, as necessary, to aid in revegetation. In areas where soil was 

removed, the disturbed areas would be scarified, ripped, or disced as necessary to 

a depth of 12 inches to ensure soil stability after replacement. In areas with viable 

sagebrush, the soil would not be ripped and seed would be broadcast and worked 

in by appropriate means, such as a harrow, drag, or rake. Similar to reclamation 

of the mine units, a tractor may be needed for surface preparation of compacted 

areas. 

Soil Replacement 

Excavated soils would be replaced at the location from which they were 

excavated, unless the area from which the soils were excavated was approved for 

a different post-mine land use (e.g., the BLM requests that a road or building 

remain in place and that request is approved by the WDEQ-LQD). In such a case, 

the excavated soil from the road or building area would be used in another area 

where the original topsoil depth was thin or non-existent (e.g., it was disturbed by 

historic exploration activities), if such replacement was approved by the WDEQLQD and the BLM. 

The replaced soil thickness would be in accordance with the depths and acreages 

salvaged during Construction. The replacement would be along the contour, 

where necessary to prevent soil erosion. To avoid clods, soils would not be 

replaced when the ground is wet or frozen. The replaced topsoil would be disced

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to create a proper seed bed. Similar to reclamation of mine units, a small backhoe 

and grader may be needed for topsoil replacement. 

Seed Mix, Reseeding Methods, and Fencing 

Vegetation would be re-established with the approved seed mix, which would 

adequately support the post-operational land uses, livestock grazing and wildlife 

habitat, and was approved by the BLM Rawlins Office on January 14, 2010 and 

WDEQ-LQD (Section RP 4.5.4 of the WDEQ-LQD Permit (LCI, 2011b). If any 

of the approved seed were unavailable or prohibitive in cost at the time of 

seeding, other locally adapted and certified seed would be substituted with prior 

approval of the BLM and the WDEQ-LQD. On occasion, soil may be stabilized 

by planting a vigorous annual cover crop of rhizomatous species as directed in 

WDEQ-LQD Guideline No. 2 (1997), in which case, LCI would seek and receive 

approval from the BLM and the WDEQ-LQD before planting such species. 

Three methods of seeding, drill, pit, and broadcast, would be used. Seeding 

would be performed as a continuous operation when conditions allow. In general, 

seeding would be completed during the spring or fall, whichever is the first 

normal period for favorable planting after the seed bed preparation. 

Drill seeding would be the primary method. Areas with little gradient would be 

seeded with the rows perpendicular to the direction of the prevailing wind. Where 

necessary to prevent erosion, seeding would be done along the contour. 

Broadcast seeding would be performed on any steep slopes and drainage areas 

that may be disturbed in the Permit Area. The seed would be distributed 

uniformly over the area using a mechanical seed spreader. Immediately after 

broadcast seeding, the areas would be raked or dragged along the contour. This 

would cover the seeds with approximately one-quarter inch of soil. Pit seeding 

would be used in areas in which vegetation re-establishment was particularly 

difficult because the method allows for sheltering of seeds from eolian erosion 

and for capturing moisture in the area of the seed. 

When reseeding areas outside fenced mine units or the Plant, vehicular access to 

reseeded areas would be restricted until vegetation was successfully reestablished. Because of the potential for excessive grazing pressure on these 

areas, revegetation success would be evaluated in each growing season to 

determine if additional weed control, a cover crop, or other protective measures 

would be necessary. If such measures were considered necessary, LCI would 

submit a plan to the BLM and the WDEQ-LQD. 

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2.0 PROPOSED ACTION AND ALTERNATIVES

Revegetation Success 

Revegetation would be deemed complete no earlier than the fifth full growing 

season after seeding and when: 

x the revegetation was self-renewing under the site conditions; 

x the total vegetation cover of perennial species (excluding noxious weed 

species) and any species in the approved seed mix was at least equal to the 

total vegetation cover of perennial species (excluding noxious weed 

species) of the undisturbed portions of the Permit Area; 

x the species diversity and composition were suitable for the postoperational land uses; and 

x the total vegetation cover and species diversity and composition were 

quantitatively assessed in accordance with procedures approved by the 

WDEQ-LQD. 

Because many of the reclaimed areas would be relatively small in comparison 

with the Permit Area and because of the similarity of the vegetation communities 

at the site, LCI would delineate a comparison area in an undisturbed portion of the 

site at least six months prior to evaluation of revegetation success. In addition, 

LCI would describe the quantitative methods to be used for comparing the total 

vegetation cover in the reclaimed and undisturbed areas and for evaluating species 

diversity and composition. These methods, as well as the size and location of the 

comparison area, would be submitted to the WDEQ-LQD for review and approval 

at least six months prior to the fifth full growing season. 

Financial Assurance

Prior to the start of the Project, LCI would be required to establish and maintain a 

reclamation performance bond, in an amount approved by the NRC, the BLM, 

and the WDEQ-LQD, to cover the costs for a third party to complete groundwater 

restoration, radiological decontamination, facility decommissioning, and surface 

reclamation. Under order of forfeiture, the bond would be payable to the State of 

Wyoming or the US Secretary of Interior (under which BLM operates). The bond 

amount would be reviewed annually by the NRC, the BLM, and the WDEQ-LQD 

and adjusted to reflect changes in cost and in the Project, including construction 

and operation activities planned for the next year. Once the NRC, the BLM, and 

the WDEQ-LQD approved the bond amount, LCI would submit an irrevocable 

letter of credit or other approved surety instrument to the WDEQ-LQD, which is 

the designated agency for holding the bond. Additional details about the bond are 

provided in Section 2.1.1.1.8 of the NRC SEIS (2011a) and Section RP 5.0 of the 

Reclamation Plan in the WDEQ-LQD Permit to Mine (LCI, 2011b). The 

calculated bond amount for the first year of the Project, including the Plant and a 

portion of Mine Unit 1, is $6,151,685, as detailed in Table RP-4 of the WDEQLQD Permit to Mine (LCI, 2011b). 

2-34 FINAL EIS – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT – VOLUME I 

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2.0 PROPOSED ACTION AND ALTERNATIVES

2.1.6 Schedule 

Figure 2.1-8 provides the current estimated chronology of the Project and 

illustrates the progressive development and restoration of the mine units up to 

final reclamation. For the purposes of this EIS, and for correlation with the NRC 

SEIS, the Project is described in three phases: Construction, Operation 

(Production), and Reclamation, because of the similarities in the activities and 

impacts. These phases are sequential with respect to the Plant and each mine unit; 

however, because of the progressive development of the mine units, there is 

overlap among the mine units (e.g., the first mine unit is in reclamation when the 

third mine unit is in development). Therefore, the discussion of the schedule 

includes the following: 

x Construction 

o Initial Construction 

o Mine Unit Development 

x Operation (Production) 

x Reclamation 

o Mine Unit Restoration and Reclamation 

o Final Reclamation 

2.1.6.1 Construction 

Initial Construction

The major facility construction, including the Plant, access roads, equipment 

staging areas, and UIC Class I wells, would be accomplished during the first year, 

with the exception of the first deep well that was drilled in 2008. 

Mine Unit Development 

The schedule generally provides two years for development of a mine unit, 

including provisions for drilling restrictions to protect wildlife and for submittal 

of the Hydrologic Test Plan and Report for the mine unit to the WDEQ-LQD for 

review and approval. The time requirement for mine unit development is a 

function of manpower and drill rigs dedicated to the task. The driver for the 

development timeline is the production schedule. Many aspects of the 

development time line can be adjusted as needed by increasing or decreasing the 

quantity of drilling rigs and people dedicated to the task. Figure 2.1-8 reflects an 

approximate 24-month plan to complete the development work as follows: 

x Monitor Well Installation: Typically 60 to 70 wells, plan two drill rigs for 

five months; 

x Pump Test and Sampling: Allow for three months; 

x Mine Unit Application Preparation: Allow for two months; 

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x Injection/Production Well Installation: Typically, nine header houses per 

unit, 60 wells per header house, requires ten drill rigs to complete one 

header house in approximately 40 days, allow for 13 months total; and 

x Construction (header houses and pipelines): Allow one month per header 

house and associated pipelines (final header house completed in 

Month 24). 

2.1.6.2 Operation (Production) 

Mine units are generally developed and activated in stages. Commonly, new 

production is staged in the level of header houses, rather than staging in complete 

new mine units. Depending on available pipeline and Plant capacity, an operator 

may initiate new production in areas as discrete as individual patterns. Production 

begins once injection of lixiviant begins. The total time for production of a 

pattern is dependent on: the efficiency of the areal sweep of the lixiviant; the 

effectiveness of the oxidation of the uranium in place; and the injectivity and 

productivity of the formation (well flow rates). The factors below were 

incorporated into the estimation of the average time for economic production 

from a pattern of the Project. 

x Production Rate: 32 gpm per production well, based on hydrologic results 

of several formation characterization tests; 

x Pore Volumes (PV): The estimated number of PVs processed to achieve 

economic depletion of the pattern is approximately 60; 

x Recovery Percentage: The percentage rate, based on laboratory tests, 

would be a 84-to-93-percent recovery rate; however, an 80-percent 

recovery rate was used for calculations; and 

x Production Grade: The grade at which a pattern is expected to be turned 

off because the lixiviant grade has diminished to an uneconomic level was 

selected to be 10 mg/L U3O8 for the purpose of the production model. 

Using the above information, the required time for economic depletion of a single 

pattern is calculated to be 12 months. Therefore, production in a mine unit is 

modeled to be completed 12 months after the initiation of production in the last 

developed header house in the unit. There is commonly a delay between the 

completion of development and the commencement of production at a given 

header house as determined by the availability of flow capacity within the process 

facility, specifically the ion exchange section. Figure 2.1-8 was developed on the 

premise that the header houses within a mine unit would be activated in stages 

and that the final header house would be activated approximately one year after 

the first. Consequently, each mine unit would have an expected production life 

cycle of two to three years. 

The water balance variations for the Project are included in Figure 2.1-9 through 

Figure 2.1-14. The various water balance scenarios presented contemplate the 

possible operational modes that a typical ISR facility may encounter over the life 

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2.0 PROPOSED ACTION AND ALTERNATIVES

of a project. By analyzing each scenario, it can be demonstrated that the facility 

would be designed to manage the water flow variations from maximum Plant use 

(Figure 2.1-11) to minimum Plant use (Figure 2.1-14). 

One PV is equivalent to the sum of: 

x the volume of water within the pattern area (thickness of the completion 

interval times surficial pattern area times effective porosity of the sand); 

x the volume of water outside of the pattern area affected by the ‘horizontal

flare’ of the lixiviant along the outer edge of the pattern area; and 

x the volume of water above and below the completion interval affected by 

the ‘vertical flare’ of lixiviant. 

Each mine unit has a unique PV, although the mine units within the Permit Area 

are anticipated to have similar PVs because of similar hydrogeologic 

characteristics within the Permit Area and the projected Plant capacity. For the 

Project, the PV of the first mine unit is calculated as 35.6 million gallons (Table

RP-4 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). 

2.1.6.3 Reclamation 

Mine Unit Restoration and Reclamation 

The schedule includes two years for groundwater restoration in each mine unit, 

based on 0.3 PV of groundwater sweep, 6.0 PV of RO, and 1.0 PV of 

recirculation. The time provided for aquifer restoration includes approximately: 

two months for each header house to serve as a buffer area between impacts of 

production and restoration; nine months for groundwater sweep; twelve months 

for RO; and one month for recirculation. The estimated number of PVs required 

for restoration and, in turn, the schedule, are based on experience at other ISR 

projects in Wyoming. The analogous projects and comparison with the Project’s

setting are described in Section RP 2.3.3 of the WDEQ-LQD Permit to Mine 

(LCI, 2011b) and Attachment 6.2-1 of the NRC Technical Report (LCI, 2010). 

The schedule also includes one year for surface reclamation of each mine unit. 

This includes time for the well abandonment, radiological surveys per NRC 

requirements, removal of surface facilities, and surface preparation and seeding 

described in Section 2.1.5. Revegetation success would be monitored after 

seeding, and in the fifth full growing season after planting, the vegetation would 

be compared against the revegetation success criteria (Section 2.1.5 and Section 

RP 4.5.5 of the WDEQ-LQD Permit to Mine [LCI, 2011b]).

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Final Reclamation

The schedule includes two years for decommissioning the Plant equipment, 

radiological surveys per NRC requirements, removal of the Plant structures, and 

surface preparation and seeding described in Section 2.1.5. Revegetation success 

would be monitored after seeding, and in the fifth full growing season after 

planting, the vegetation would be compared against the revegetation success 

criteria (Section RP 4.5.5 of the WDEQ-LQD Permit to Mine (LCI, 2011b). 

2.1.6.4 Schedule Adjustments 

The schedule could be affected by various factors that would typically involve 

adjustments to meet production schedules and contractual agreements, longer (or 

shorter) than predicted mining or restoration times, or delays in mine unit 

installations. In addition, if an area undergoing restoration is directly adjacent to 

an area undergoing mining, all or a portion of the restoration unit could be serving 

as a buffer zone, or could be in the final stage of restoration (stability monitoring). 

The schedule may also be affected by restrictions to protect wildlife. 

The current schedule reflects existing restrictions on drilling, and LCI would keep 

in contact with the BLM and the WGFD for updated guidance. 

To account for schedule changes, LCI would include in the Annual Report to the 

WDEQ, the NRC, and the BLM a map of the Permit Area showing: the mine 

units that are being developed, in production, and in restoration; and areas where 

restoration has been completed. New areas where production or restoration is 

expected to begin in the next year would also be identified. The actual schedule 

would be compared with the projected schedule, and if it becomes evident that 

LCI cannot comply with the approved schedule, a request for revision of the 

schedule would be made, including explanation of the reason(s) for the changes 

from the approved schedule. 

2.1.7 Monitoring 

LCI would be required to conduct monitoring related to the Project. These 

requirements are mandated by various regulations and permits, including: State 

wildlife protection regulations; air and water quality regulations; and the permits 

from the WDEQ-AQD, the WDEQ-LQD, and the NRC. In addition to the 

baseline monitoring required for the permits (Section 3.0), the following would 

be monitored during the Project: 

x air quality; 

x archaeology and cultural resources; 

x equipment performance (e.g., safety, effluent control, mine unit balance, 

and pipelines); 

x groundwater; 

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2.0 PROPOSED ACTION AND ALTERNATIVES

x health (radiation-related); 

x soils; 

x surface water; 

x transportation; 

x vegetation; and 

x wildlife. 

Some monitoring would be conducted for the life of the Project, while other 

monitoring would depend on the phase of the Project. Construction would 

include the Initial Construction of the Plant and other life-of-mine facilities and 

the Mine Unit Development, i.e., progressive construction of mine units. 

Operation would include the productive time of each mine unit and the on-site 

processing of the product. Reclamation would include the Mine Unit Restoration 

and Reclamation, as well as the Final Reclamation of the Project facilities. Table 

2.1-2 outlines the monitoring activity that would occur during each phase of the 

Project, and additional details for each resource are included in Section 4.0.

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Table 2.1-2 Project Monitoring (Page 1 of 5)
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IN-SITU RECOVERY PROJECT – VOLUME I 

Table 2.1-2 Project Monitoring (Page 2 of 5) 
July 20

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Table 2.1-2 Project Monitoring (Page 3 of 5) 
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IN-SITU RECOVERY PROJECT – VOLUME I 

Table 2.1-2 Project Monitoring (Page 4 of 5) 
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Table 2.1-2 Project Monitoring (Page 5 of 5)