EXECUTIVE SUMMARY

FINAL EIS – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT – VOLUME I ES-1 

July 2012 

EXECUTIVE SUMMARY 

This Executive Summary is intended to provide a brief overview of the Proposed 

Action, alternatives, and conclusions from the impact analyses. For the 

supporting documentation and detailed analyses, please see the full 

Environmental Impact Statement (EIS). 

PROJECT OVERVIEW AND LOCATION 

Lost Creek ISR, LLC (LCI) is proposing the construction, operation, and 

reclamation of facilities for In-Situ Recovery (ISR) operations within the Lost 

Creek Permit Area (Permit Area) of the Lost Creek Uranium In-Situ Recovery 

Project (Project). ISR involves the use of a recovery solution, known as a 

lixiviant, to extract the mineral from the geologic formation, and the mineral is 

removed from the solution using ion exchange resins at the processing facility 

(the Plant). ISR occurs without physically removing the ore-bearing strata. 

Under the Proposed Action, about six million pounds of uranium would be 

produced from the Permit Area. The Proposed Action would occur over a 12-year 

period, including about seven months for initial construction, seven years for 

production, and the remaining time for final reclamation. With appropriate 

regulatory approval, the Plant could also be used to process ion exchange resins 

from other ISR mines in the region after completion of mineral recovery in the 

Permit Area. 

The Permit Area is located in northeast Sweetwater County, south-central 

Wyoming. Rawlins is 38 miles southeast; Rock Springs is 80 miles southwest; 

Casper is 90 miles northeast; and Jeffrey City is 25 miles north. The nearest 

population center, located 15 miles northeast of the Permit Area, is Bairoil, with a 

population of about 100 people. A series of paved and unpaved roads across 

state, private and Bureau of Land Management (BLM) public land provide access 

to the Permit Area, which is located about 21 miles from the nearest highway 

(State Highway 73). There are no publicly maintained roads within the Permit 

Area. The Permit Area is geographically located in the north-central portion of 

the Great Divide Basin. The regional rolling landscape has draws, rock 

outcroppings, ridges, and bluffs. The Permit Area is characterized by low relief 

sagebrush-dominated plains dissected by small, ephemeral drainage networks. 

The site elevation ranges from approximately 6,790 to 7,050 feet above mean sea 

level. 

There are grazing allotments in the Permit Area. Farms, residences, and 

population centers are not present. The closest mining project is Kennecott 

Uranium Company’s Sweetwater Project, about three miles south-southwest of 

the Permit Area. The Sweetwater Project once included an open pit mine, which 

targeted a different ore zone than the Proposed Action, and a conventional mill. 

The mine was reclaimed by the operator and the mill is on standby. Oil and gas 
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exploration has been conducted in the vicinity, but the closest existing or 

proposed production is at least seven miles to the south-southwest. 

The Permit Area covers about 4,254 acres for adequate spacing of facilities and to 

encompass the ore trend, which extends east-west. Eighty-five percent of the 

Permit Area is public land managed by the BLM Rawlins and Lander Field 

Offices. The Permit Area includes 201 unpatented federal lode claims. Fifteen 

percent of the Permit Area (the northeast portion of the Permit Area) is owned by 

the State of Wyoming and subject to state mineral lease. Under the Proposed 

Action, the projected surface disturbance is about 345 acres, and the majority of 

the Project’s activities would occur on public land. 

Pursuant to Title 43 of the United States (US) Code of Federal Regulations (CFR) 

Subpart 3809, which applies to operations authorized by mining laws on public 

lands, LCI submitted a Plan of Operations to the BLM in November 2009. The 

Plan of Operations essentially constitutes the Proposed Action in this EIS. The 

most current information on the Project is included in the Wyoming Department 

of Environmental Quality, Land Quality Division’s (WDEQ-LQD) Permit to 

Mine (LCI, 2011b). Although the Permit to Mine evaluates environmental 

impacts of the Proposed Action, the requirements of the National Environmental 

Policy Act of 1969 (NEPA) must be fulfilled by a federal agency. The Nuclear 

Regulatory Commission (NRC) prepared a Generic EIS (GEIS) and Supplemental 

EIS (SEIS) for the Project, and issued LCI a Source and Byproduct Material 

License in August 2011. In order to support the BLM’s NEPA requirements and 

regulatory authorities, the BLM prepared this EIS to focus on the issues and 

mitigation measures not analyzed in sufficient detail in the NRC NEPA 

documents. The BLM is the lead agency for this EIS. 

Purpose and Need 

Expanding nuclear power is a key component of the Energy Policy Act (EPACT 

2005) signed into law in 2005. The policy calls for federal agencies “to develop a 

national energy policy designed to help the private sector, and, as necessary and 

appropriate, State and local governments, promote dependable, affordable, and 

environmentally sound production and distribution of energy for the future.” 

Exploration and development of locatable federal minerals by private industry is 

part of BLM’s minerals program under the authority of 43 CFR 3800, Mining 

Claims Under the General Mining Laws, the Mining and Minerals Policy Act of 

1970, the Federal Land Policy and Management Act of 1976 (FLPMA), and the 

National Materials and Minerals Policy, Research, and Development Act of 1980. 

The Project’s objective would be to produce an estimated six million pounds of 

uranium over an operating period of 12 years. Taking into account the BLM’s 

multiple-use mandate, the purpose and need for this EIS is to analyze the sitespecific impacts associated with the Proposed Action and its alternatives, identify 

mitigation measures to potentially reduce or eliminate those impacts, and provide 
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July 2012 

agency decision makers with detailed information upon which to base their 

decision. 

Lost Creek ISR, LLC Interests and Objectives 

The Proposed Action would allow LCI to mine a valuable uranium deposit under 

the authority of the US mining laws, while ensuring that operations are conducted 

in a manner that prevents unnecessary or undue degradation of public lands in 

conformance with BLM requirements. The Project would also support energyindependence and environment-awareness policies. 

Decisions to be Made 

The authorized official with the BLM will decide whether or not to approve the 

proposed development of federal minerals (uranium) within the project referred to 

as the Lost Creek Uranium In-Situ Recovery Project, and if so, the approval will 

contain changes or conditions that are necessary to meet the performance 

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

per 43 CFR 3809.411(d). 

Applicable Statutes, Regulations, and Associated Requirements 

ISR projects, such as the Lost Creek Uranium In-Situ Recovery Project, must 

conform to several statutory and regulatory programs and their associated 

requirements to address environmental and operational concerns. The BLM 

programs and requirements to which the Project must conform include: federal 

guidelines for implementing NEPA; the Council on Environmental Quality 

Regulations for Implementing the Procedural Provisions of NEPA outlined in 40 

CFR Parts 1500 to 1508; Department of Interior Regulations 43 CFR Part 46; 

Department of the Interior and BLM policies and manuals; the Minerals Goal and 

Objectives in Section 2.3.7 of the Rawlins Resource Management Plan (RMP); 

the provisions of the Lander RMP for the Green Mountain Management Unit; 

Invasive Plant Management; the Grazing Plan for the Green Mountain Common 

Allotment; and the Wyoming Standards for Healthy Rangelands. 

Section 1.4.3 outlines other federal, state, and county requirements. Table 1.4-1

provides an overview of the federal, state, county, and local laws applicable to 

uranium development and the key regulatory requirements that would govern 

project implementation. 

THE PROPOSED ACTION AND ALTERNATIVES 

The Proposed Action 

This uranium ISR operation would extract the mineral from permeable, uraniumbearing sandstones through a series of mine units. The mine units follow the ore 
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deposits delineated by exploration drilling. The deposits generally occur at depths 

of 300 to 700 feet below the ground surface in long, narrow trends varying from a 

few hundred to several thousand feet long and 50 to 250 feet wide. 

The ISR operation essentially reverses the natural processes that deposited the 

uranium. During mining (also called operation or production), lixiviant is 

pumped from a processing facility (the Plant) through buried pipelines to the 

injection wells in the operational mine unit(s). The lixiviant oxidizes the uranium 

mineral, allowing dissolution of uranium in groundwater. After circulation 

through the production zone (i.e., from the injection wells to the production 

wells), the resulting uranium-laden solution is pumped from the production wells 

in the mine unit(s) through buried pipelines to the Plant. There, the uranium is 

recovered by a series of circuits (e.g., ion exchange, elution, precipitation) and 

prepared for shipment as either a yellowcake slurry or dried yellowcake. The 

lixiviant is regenerated and pumped back to the mine unit(s) to recover additional 

uranium. Storage ponds are used in conjunction with Underground Injection 

Control (UIC) Class I wells for waste water disposal at depths between 6,139 and 

9,590 feet below the ground surface. 

After mining, groundwater restoration essentially reverses the effects of oxidation 

to re-establish the reducing conditions that were present prior to mining. 

Restoration methods include groundwater sweep, reverse osmosis, recirculation, 

and, if site conditions are suitable, groundwater transfer, reductant addition, and 

biorestoration. Groundwater monitoring during active restoration and during a 

subsequent stability phase is used to confirm that restoration criteria have been 

met. 

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 Project schedule includes: 

x Construction 

o Initial Construction 

o Mine Unit Development 

x Operation (Production) 

x Reclamation 

o Mine Unit Restoration and Reclamation 

o Final Reclamation 

Initial Construction would occur during the first year of the Project and include: 

the major facility construction, in particular, the Plant (including the office, 

Storage Ponds, and other associated structures), equipment staging areas, main 
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July 2012 

pipelines, and transmission line; improvement of the access roads; drilling of the 

UIC Class I wells (except the first deep well that was drilled for testing in 2008); 

and installation of additional equipment for air and water quality monitoring. 

Development of the first mine unit, which would take about two years, would 

overlap with the Initial Construction. The scale and number 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. Three 

mine units are anticipated for the Proposed Action, and each mine unit has an 

expected production cycle of about two to three years. Development of the next 

mine unit would begin during production of the previous mine unit. 

Each mine unit consists of patterns of production and injection wells within a ring 

of monitor wells. (In the Proposed Action, the injection wells are expected to be 

spaced 75 to 150 feet apart.) For mining efficiency and to avoid an excursion 

(unanticipated movement of lixiviant), a series of procedures would be in place, 

including regular balancing of the pattern production and injection rates, water 

level monitoring, and pressure and flow measurements. In addition to pattern 

balancing, water quality samples would be collected from the ring of monitor 

wells and analyzed to detect a horizontal excursion in the production zone. (In 

the Proposed Action, the monitor well ring is anticipated to be spaced about 500 

feet from the pattern area. The distance between each monitor well in the ring is 

anticipated to be about 500 feet, although actual distances would be based on the 

aquifer characteristics of the mine unit to ensure any excursion can be detected in 

a timely manner.) Water quality samples would also be collected from monitor 

wells completed in overlying and underlying aquifers to detect a vertical 

excursion. (These wells would be located within the mine unit boundary at a 

density of about one overlying and one underlying well per four acres, depending 

on the hydrologic characteristics of each mine unit.) In addition, monitor wells 

located within the pattern area and completed in the production zone would 

provide information on the mining process. 

During the Proposed Action, approximately 345 acres total within the 4,254-acre 

Permit Area would be fenced to keep out cattle and wild horses. 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. A total of ten acres of the 

Plant area would be fenced. About eight acres of the Plant area would be fenced 

to keep out cattle and wild horses; the remaining two acres of the Plant area 

would be fenced to keep out wildlife, cattle, and wild horses from the Storage 

Ponds. 
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Mine Unit Restoration and Reclamation begins when technical, economic, and 

operational criteria indicate uranium recovery in a mine unit is completed. 

Restoration and reclamation of each mine unit includes: 

x groundwater restoration, 

x radiological decontamination, 

x equipment removal/decommissioning (e.g., well abandonment), and 

x surface reclamation (e.g., well site reseeding). 

Groundwater restoration in each mine unit would require about two years, and 

decontamination and equipment removal and decommissioning would require 

about one year. Surface reclamation would occur immediately afterwards, and 

monitoring to ensure revegetation success would be required until at least the fifth 

full growing season after seeding. 

Final Reclamation, including facility decontamination and decommissioning and 

surface reclamation, would occur once the Plant is no longer in use and would 

require about two years. As with Mine Unit Reclamation, monitoring of 

revegetation success would be required until at the least the fifth full growing 

season. 

Alternatives to the Proposed Action 

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 the BLM’s review of the Proposed 

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

and collaboration with federal, state, and local agencies, as well as tribal 

governments. 

Alternatives Evaluated in Detail 

The alternatives that were considered and evaluated in detail include: 

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

Current land uses (livestock grazing, wildlife habitat, dispersed recreation, 

minerals and energy development, and infrastructure) would not be 

expected to change. LCI would continue exploration activities, which 

would involve reclamation of disturbance associated with LCI’s Drilling 

Notification, but no uranium would be produced from the Permit Area. 

x Not Fencing the Pattern Areas – If the pattern areas were fenced to reduce 

damage to wells, grazing would not be possible in the pattern areas. Also, 
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July 2012 

if a gate were left open, cattle or wild horses could be injured if they 

entered the pattern area and were startled. Therefore, the alternative of 

‘not fencing the pattern areas’ was evaluated in detail. Even if the pattern 

areas were not fenced, about ten acres of the Plant would still be fenced to 

keep out cattle and wild horses, and two of the ten acres would also be 

fenced to keep out wildlife around the Storage Ponds. 

x Drying Yellowcake On-Site (Preferred Alternative); also evaluated in the 

NRC SEIS – This alternative is the same as the Proposed Action with the 

addition of a yellowcake drying-packing facility in the Plant. As with the 

Proposed Action, yellowcake slurry would be produced. However, rather 

than shipping the slurry off-site for drying, the slurry would be filterpressed to remove additional water, dried under vacuum, and packaged 

(also under vacuum) in drums for off-site shipping to a fuel processing 

facility. Emissions from the drying chamber would be treated through a 

bag filter to remove yellowcake particulates; and any water vapor exiting 

the drying chamber would be cooled and condensed. The condensate 

volume from the dryer would be minimal and re-used in processing or 

disposed of through the disposal system used during slurry production. 

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 BLM 

selects the Drying Yellowcake On-Site Alternative as the preferred 

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

alternative which the BLM believes would fulfill its statutory mission and 

responsibilities, giving consideration to economic, environmental, 

technical and other factors. This action involves drying the mineral 

solution into a solid yellowcake form within the plant. Housing the 

drying-packing facility within the processing plant would reduce 

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

wildlife disturbances, and cleaner air quality. 

Alternatives Considered and Eliminated from Detailed Study 

Alternatives considered and eliminated from detailed study are listed below, along 

with the primary reason(s) for elimination: 

x Portable Drill Pits and Closed Loop Drilling Systems – Limited to no 

reduction in surface disturbance, increased transportation and wildlife 

impacts, and increased costs and logistical difficulties; 

x Alternative Mining Methods (also an alternative eliminated from detailed 

analysis in the NRC SEIS [2011a]) – Significantly greater surface 

disturbance (with corresponding increases in soil, vegetation, and wildlife 
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impacts), increased groundwater consumptive use, and increased health 

and safety risks; 

x Alternative Waste Water Disposal Methods (discussed in the NRC 

SEIS) – Significantly increased surface disturbance, less efficient (or no) 

operation during adverse weather, and increased impacts to land use, 

vegetation, and wildlife; 

x Phased Development of Mine Units – Not economically viable and 

constrains options for more efficient mining and groundwater restoration; 

x Alternative Lixiviants (also an alternative eliminated from detailed 

analysis in the NRC SEIS) – Geologic setting and geochemical conditions 

restrict use; 

x Shipping Uranium-Laden Resin – Increased transportation impacts (with 

corresponding increases in air quality and wildlife impacts); 

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

license application and WDEQ-LQD permit application) – Interference 

with potential mine unit development and closer to active raptor nest; and 

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

evaluated by the NRC, WDEQ-LQD, and WGFD) – Increased surface 

disturbance (with corresponding increases in vegetation, surface water, 

and wildlife impacts). 

PUBLIC INVOLVEMENT 

In February 2010, the BLM provided a news release about the Lost Creek Plan of 

Operations, which was received in November 2009, and projected environmental 

review. The public scoping period for NEPA commenced when the Notice of 

Intent (NOI) to prepare an EIS was published in the Federal Register (FR) on 

February 11, 2011 (76 FR 7877). Notification of the scoping process was also 

published in local newspapers and was included in the BLM’s weekly report to 

the Washington, DC office as well as the BLM’s quarterly congressional briefing. 

The US Fish and Wildlife Service (USFWS), Environmental Protection Agency 

(EPA), State of Wyoming, state and local government representatives, Native 

American tribes, local media, and interested organizations and individuals also 

received a public scoping notification via email or mail. A public scoping 

meeting was held at the BLM Rawlins Field Office on March 7, 2011. Media 

interviews were conducted with The Radio Network, which operates a syndicated 

string of radio stations in southwest Wyoming. 

Organizations and agencies were mailed letters of invitation to become 

cooperating agencies in the Project’s EIS development process. These 

organizations included: USFWS; Arapahoe Tribe; Shoshone Tribe; Ute Tribe; 

State of Wyoming and its agencies; Carbon County Commissioners; Fremont 

County Commissioners; Sweetwater County Commissioners; and members of the 

Coalition of Local Governments. The EPA requested to become a cooperating 

agency in the NEPA process. The following agencies with jurisdiction, special 

expertise, or interest in the EIS development process agreed to participate as 
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cooperating agencies: EPA; State of Wyoming and its agencies; Carbon County 

Commissioners; and Sweetwater County Commissioners. 

Since the Project has completed the permitting processes for the NRC, WDEQ, 

and Sweetwater County, public meetings for the Project had been held prior to the 

BLM’s public scoping meeting. For NRC to meet its NEPA requirements, NRC 

prepared a GEIS for uranium ISR and an SEIS for the Project, both of which 

included public scoping and comment periods (NRC and WDEQ, 2009; NRC, 

2011a). For the GEIS, the NRC staff held three public scoping meetings from 

July 24, 2007, to November 30, 2007, and accepted public comments on the scope 

of the GEIS published as a final report in May 2009. Additionally, NRC held 

eight public meetings to receive comments on the draft GEIS, published in July 

2008. Three of these meetings were held in the State of Wyoming. Comments on 

the draft GEIS were accepted between July 28, 2008, and November 8, 2008 

(NRC, 2011a). 

As part of the preparation for the SEIS, the NRC staff met with federal, state, and 

local agencies and authorities during a site visit to the proposed Permit Area and 

vicinity in January 2009. The NRC gathered additional site-specific information 

to assist with the environmental review and to determine whether site-specific 

information was consistent with the GEIS. The NRC staff also contacted 

potentially interested Native American tribes and local authorities, and public 

interest groups in person and via e-mail and telephone (NRC, 2011a). 

A Notice of Opportunity for Hearing on the proposed Project license application 

was published by the NRC on July 10, 2008 (73 FR 39728). No hearing requests 

were received. NRC staff published an NOI to prepare the SEIS on September 3, 

2009 (74 FR 45656) (NRC, 2011a). On December 11, 2009, NRC published a 

Notice of Availability (NOA) for the draft SEIS for the proposed Project (74 FR 

65806), and on February 5, 2010, NRC extended the public comment period to 

March 3, 2010 (75 FR 6065). In addition to the opportunities provided through 

the NEPA process, NRC provided multiple opportunities for public involvement 

during the NRC staff’s safety review. Specifically, the NRC staff held six 

meetings or teleconferences with the applicant from 2006 through 2010. Each of 

these activities included an opportunity for public comment (NRC, 2011a). 

The WDEQ permitting processes also require public notice and comment (Air 

Quality Division, Wyoming Air Quality Standards and Regulations, Ch. 6, Sec. 

2(m); LQD, NonCoal Rules and Regulations, Ch. 11, Sec. 21; Water Quality 

Division, Water Quality Rules and Regulations, Ch. 13, Sec. 19), and these 

requirements have been met for the Project, including notice and opportunity to 

participate in the Wyoming Environmental Quality Council (EQC) Hearing on the 

WDEQ-LQD Permit in August 2011 (resulting in the EQC upholding the WDEQLQD decision to issue the permit) (EQC, 2011). Public meetings were also 

conducted in Sweetwater and Carbon Counties to meet planning requirements or 

for public information (LCI, 2009). 
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IDENTIFICATION AND ANALYSIS OF ISSUES 

Issues and concerns were identified through consultation and coordination with 

federal, state, and local agencies, and interested groups and individuals. The 

BLM Rawlins Field Office resource specialists also reviewed the Proposed Action 

and identified issues and concerns related to certain aspects of the human 

environment and other resources. Based on this coordination, the BLM 

determined that the following issues are key areas for assessment in the EIS: 

Rangeland (Land Use)

Issues - Confirm that all grazing permittees directly or indirectly affected by the 

Project are aware of the issues, decisions and resulting actions regarding 

the Project and that the Project is in conformance with existing Grazing 

Plans. Ensure that impacts to vegetation (including introduction of 

noxious and invasive species) and to soils are identified and appropriate 

procedures for minimization and mitigation of impacts are in place along 

with procedures for reclamation and monitoring of reclamation success. 

Analysis (Grazing) - The Permit Area covers less than one percent of each of the 

Stewart Creek, Cyclone Rim, and Green Mountain grazing allotments, and 

the Project-related disturbance within the Permit Area would cover less 

than 0.2 percent of each allotment. The reduction in the total number of 

livestock that could be supported during the Project would be five head of 

cattle and two head of sheep. The Proposed Action includes reclamation 

with an approved seed mix, so the post-mining land uses, including 

grazing and wildlife habitat, can be supported. 

Public meetings on the Project have been held locally, after public notice, 

and will continue to be held locally, to help ensure local land users 

understand the Project and associated impacts. The Wyoming Department 

of Agriculture has participated in the cooperators’ meetings. 

Analysis (Vegetation) - During the Project, a total of approximately 345 acres of 

the land surface and associated vegetation could potentially be disturbed, 

which is about eight percent of the 4,254-acre Permit Area. To the extent 

possible, roads and other facilities (e.g., pipelines) would be aligned with 

existing roads to minimize additional disturbance. The disturbance 

acreage includes areas from which vegetation and topsoil would be 

removed and areas in which the vegetation would not be removed but 

could be crushed or otherwise disturbed. The disturbance would be 

progressive, i.e., it does not all occur during Initial Construction. Interim 

reclamation, used in the mine units during production, and final 

reclamation include weed control and reseeding with a regulatoryapproved seed mix suitable for the post-mine land use, which would be the 

same as the pre-mine land use. Revegetation success criteria must also be 

met, including cover and species diversity determined from baseline 

sampling and, after reclamation, from comparative sampling of 

undisturbed areas. 
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Analysis (Soils) - Procedures have been established for determining where topsoil 

must be removed, appropriate topsoil salvage depths, and short-term and 

long-term topsoil storage (e.g., short-term along pipelines and long-term 

where soil is removed from building footprints). Procedures have also 

been established for topsoil reapplication during reclamation. 

Recreation

Issue - Ensure the Proposed Action does not require changes to existing recreation 

and off-highway-vehicle management to protect the safety of public land 

users. 

Analysis - Recreational use of the general area is relatively light and dispersed. 

The impacts to recreation would be negligible due to the small area of the 

impacts. To protect the health and safety of the public, recreationists 

would have restricted access – albeit minimal – to locations within the 

Permit Area that were previously available for general use. The Plant, 

certain mine units and other related infrastructure would be fenced. 

(Approximately 300 acres total within the 4,254-acre Permit Area would 

be fenced.) Though the general public would be restricted from certain 

portions of the Permit Area, recreationists would continue to have access 

to the general area via existing roads. Traffic on these roads would 

possibly increase due to the additional use of the roads by Project vehicles; 

however, the additional traffic volume would not be expected to greatly 

affect recreational access. 

Transportation 

Issue - Evaluate the Project influence on access to and transportation across the 

BLM lands and coordination with local entities for road maintenance. 

Analysis - The relatively minor increase in traffic would not degrade the existing 

road network nor reduce safety conditions to levels unacceptable to LCI 

(for roads on the Permit Area) or unacceptable to government agencies 

(for off-site roads). LCI is working with county and local governments to 

ensure maintenance agreements are in place. LCI would also install traffic 

counters on the smaller, improved surface roads for which no data 

currently exist. 

Wildlife 

Issues - Confirm that the potential impacts to wildlife, including threatened, 

endangered, candidate, and sensitive species, and to wildlife habitat have 

been evaluated and the monitoring and mitigation measures in the 

Proposed Action conform to current policies and procedures. 

Analysis (Wildlife Habitat) - The two major vegetation/habitat types in the Permit 

Area are the Lowland and Upland Big Sagebrush Shrublands. Of the 

acreage which would be disturbed, approximately 15 percent (which 

corresponds to about 1 percent of the Permit Area) would be the Lowland 

Big Sagebrush Shrubland habitat, which has the highest diversity and 

density of nesting birds and small mammals. As noted in the analysis of 
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Rangeland issues above, efforts would be made to minimize Project 

disturbance, which occurs sequentially throughout the Project, and ensure 

maximum revegetation success. 

Analysis (Wildlife) - Numerous species have been identified through multi-year 

baseline surveys, and continued monitoring and mitigation requirements 

would be established based on a variety of Project impacts, including 

surface disturbance, noise, and traffic. The species of primary concern are 

Greater sage-grouse and raptors. Since the Project is within a Greater 

sage-grouse Core Area, LCI initiated a more detailed Greater sage-grouse 

monitoring program for the Project and completed the Density and 

Disturbance Calculation Tool (DDCT) to evaluate potential effects of the 

Project on Greater sage-grouse (Mead, 2011 and Wyoming Interagency, 

2011). The Wyoming Game and Fish Department reviewed the DDCT 

and commented that the results indicated that the surface disturbance 

resulting from the Project was in line with State-wide stipulations for 

Greater sage-grouse, taking topography and proximity to leks into account 

(WDEQ, 2011a). The ferruginous hawk is the only raptor known to nest 

within the Permit Area. There are currently no active nests within the 

Permit Area, although Project activities would also take into account a 

one-mile buffer around nests adjacent to the Permit Area. 

Wild Horses 

Issue - Evaluate the Project influence on wild horses and ensure that monitoring 

and mitigation measures in the Proposed Action conform to current 

policies and procedures. 

Analysis - During the Project, a total of approximately 345 acres of the land 

surface and associated vegetation (eight percent of the 4,254-acre Permit 

Area) would be disturbed and subsequently reclaimed. Because wild 

horses are mobile and only a very small percentage of their range would 

be influenced, no significant impacts to the population are expected. 

Approximately 300 acres total within the Permit Area would be fenced to 

keep out cattle and wild horses during the Project. Fencing and gates 

would be constructed according to regulatory guidelines to minimize 

potential mortality or injury to wild horses and wildlife. 

Water Resources 

Issues - Evaluate the Proposed Action to ensure that potential impacts to water 

resources have been addressed and that provisions are in place for 

monitoring to detect any impacts and for mitigation of unanticipated 

adverse impacts. 

Analysis (Water Quantity) - Four BLM water wells are located outside of, but 

within three miles of, the Permit Area. The completion depths of the 

wells, based on available information, do not directly coincide with the 

depth of the ore zone targeted by the Project. Even if the completion 

depths coincided, drawdown at the BLM well locations would not exceed 

15 feet, based on a Project-specific groundwater model. LCI has also 
EXECUTIVE SUMMARY

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July 2012 

committed to mitigation if any significant impacts to the BLM water wells 

are observed (e.g., water levels drop to a point that impairs the usefulness 

of the wells). 

Analysis (Water Quality) - Because of the distance between the BLM water wells 

and the mine units and the different completion depths between the BLM 

water wells and the mine unit wells, water quality impacts to any of the 

BLM wells are not anticipated. One of the four BLM wells was sampled 

by LCI for baseline conditions and the sample contained elevated 

concentrations of uranium and radium, not unexpected given the extensive 

natural uranium deposition in this portion of the Great Divide Basin. 

Air Quality 

Issue - Evaluate the measures that will be taken during the Proposed Action to 

minimize dust generation and other potential adverse impacts to air 

quality. 

Analysis – The WDEQ Air Quality Division (WDEQ-AQD) issued an air quality 

permit for the Project, which is not considered a “major source” as defined 

in the WDEQ-AQD regulations. Under WDEQ-AQD regulations, air 

quality modeling is not necessary. Air emissions from the Project would 

comply with the conditions of the WDEQ-approved construction air 

permit and the required WDEQ minor source operating permit. Due to the 

wind and relative instability of the air, emissions would generally be 

quickly dispersed. As such, it is not expected that the predicted Project 

emissions would impact attainment for ambient air quality standards in the 

region surrounding the Permit Area. The Permit Area is more than 50 

miles upwind of the closest Prevention of Significant Deterioration (PSD) 

Class I or Sensitive Class II Areas. Therefore, emissions are not expected 

to impact air quality in these areas. LCI would use best management 

practices (BMPs) to reduce fugitive dust and emissions. These BMPs 

include a variety of actions, such as dust suppressants, engine maintenance 

and tuning, use of newer equipment, speed limits, and revegetation. 

Historical and Cultural Resources 

Issue - Ensure that the resources in the Permit Area have been identified in 

accordance with procedures established by the BLM and the Wyoming 

State Historical Preservation Office (SHPO) and that the Proposed Action 

includes protections for the resources identified in the Permit Area. 

Analysis – Based on resource inventories conducted per BLM and SHPO 

procedures, one prehistoric archaeological site recorded in the Permit Area 

would incur adverse effects. The site lies in an area where construction 

related to a mine unit, an access road, and a pipeline would occur. It is 

anticipated that the entire site would be subjected to surface scraping; 

however, mitigative excavation, in accordance with an existing approved 

plan, would take place prior to these activities. Management practices 

would also be in place to protect archaeological resources should a 

discovery of historical or cultural resources occur during the Project. 
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Visual Resources 

Issue - Ensure that the impacts identified in the Proposed Action conform to the 

objectives of the existing visual resource management (VRM) classes. 

Analysis - The largest facility, the Plant, would be discernible during the day, but 

would not be a dominant landscape feature to observers outside the Permit 

Area. Night-time operations would be minimal. Most of the areas where 

visual resources may be impacted are within the Visual Resource 

Inventory Class IV (areas with the least amount of visual value). The 

largest potential visual impacts from the Plant lie in the southwesterly to 

southeasterly directions, along county and BLM roads. The Plant would 

potentially be visible from the Continental Divide Trail, but in only very 

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

eight miles away, the Plant would not dominate the landscape. The Plant 

would also be visible along about seven miles of the Rawlins-Fort 

Washakie Stage Road, but the closest distance would be about 6.5 miles. 

Socioeconomics 

Issue - Ensure that the potentially affected counties and cities have the necessary 

infrastructure to support the development associated with the Project. 

Analysis - There would not be an increase in the local and regional population that 

would strain the ability of communities and/or counties to provide 

adequate housing and services, nor would there be an increase in the local 

or regional cost of living as a result of the Project. There would be an 

increase in government revenues to offset increased demands for services 

and an improvement in socioeconomic viability due to indirect economic 

activity (e.g., purchase of local goods). Therefore, the potentially affected 

communities and counties have expressed support for the Project. LCI has 

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

effort to sustain and improve the economies and conditions. 

COMPARISON OF ENVIRONMENTAL IMPACTS AND 

CONSIDERATION OF CUMULATIVE IMPACTS 

Table 2.3-1 summarizes the impacts of the Proposed Action and the alternatives 

evaluated in detail. The cumulative impacts that result from the incremental 

impact of the Proposed Action, when added to other past, present, and reasonably 

foreseeable future actions, were also considered. Because of limited specific 

information about future actions, primarily related to uranium, oil, and gas 

exploration and development, reasonable assumptions about the actions were used 

in the analysis. The proposed Project would not contribute perceptibly to 

cumulative impacts, due to: the dispersed locations of the actions in the northcentral portion of the Great Divide Basin; the fact that not all the actions would 

occur at once; and the current reclamation requirements, which were not in place 

during older resource exploration and development actions. 
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CONCLUSIONS 

The authorized official with the BLM will decide whether or not to approve the 

proposed development of the Project, and if so, the approval will contain changes 

or conditions necessary to meet the performance standards of 43 CFR 3809.420 

and to prevent unnecessary or undue degradation per 43 CFR 3809.411(d). The 

Preferred Alternative is the Proposed Action for ISR mining and processing, 

including a vacuum yellowcake dryer, in accordance with the WDEQ-LQD 

Permit to Mine (Permit No. 788), the NRC Source and Byproduct Material 

License (SUA-1598) and other issued agency approvals. The WDEQ-LQD 

Permit to Mine requires the BLM’s consent, and there is a Memorandum of 

Understanding between the BLM and the State of Wyoming recognizing the 

authorities and responsibilities of both agencies when permitting mining 

operations on BLM-administered lands. For example, following completion of 

the Record of Decision for this EIS, the BLM can request a license amendment or 

permit revision to incorporate new design features and/or mitigation measures that 

may be developed during this EIS. In addition, the Record of Decision is also 

enforceable in terms of compliance with, or execution of, the environmental 

protection measures listed in it (BLM, 2011g). 

The Proposed Action would allow LCI to mine a valuable uranium deposit under 

the authority of the US mining laws, while ensuring that operations are conducted 

in a manner that prevents unnecessary or undue degradation of public lands. The 

Project would be constructed and operated to avoid and minimize adverse 

environmental impacts, and timely reclamation is required to further reduce 

impacts. Baseline information on vegetation, soils, surface water, wildlife, land 

use, and other resources has been collected, as summarized in this EIS. 

Regulatory requirements and operator initiatives for resource protection and 

reclamation, including minimization of surface disturbance, topsoil handling and 

replacement, vegetation re-establishment, and wildlife monitoring and protection 

stipulations, are also summarized in this EIS. ISR mining requires groundwater 

withdrawal and changes in groundwater quality; however, there would be no 

interference with existing water uses, and groundwater restoration to a quality 

consistent with pre-mining uses is required. As a result of baseline data analysis 

and interpretation, operational procedures, and reclamation requirements, 

environmental impacts are anticipated to be minimal. Project-wide resource 

monitoring during the life of Project is required to confirm that actual Project 

impacts are consistent with the environmental impacts disclosed in this EIS. 

Additional details in the WDEQ-LQD Permit to Mine and NRC License are 

referenced, where appropriate. 

The Project is unlikely to have adverse effects on public health, welfare, and 

safety because of the monitoring and protections required by the NRC and other 

agencies. Adverse socioeconomic impacts, e.g., excessive housing demand, 

would be minimal because of the relatively small size of the Project. Benefits to 
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July 2012

the state, counties, and local communities would include tax revenues, 

employment opportunities, and indirect economic activity.