Record of Decision for the 

Lost Creek Uranium In-Situ Recovery Project, 

Sweetwater County, Wyoming 

October 2012 

B

L

M 

 High Desert District 

– Rawlins Field Office, Wyoming Hi

gh Desert District – Rawlins Field Office, Wyoming
Mission Statement 

The BLM’s multiple-use mission, set forth in the Federal Land Policy and Management Act of 

1976, mandates that we manage public land resources for a variety of uses, such as energy 

development, livestock grazing, recreation, and timber harvesting, while protecting a wide 

array of natural, cultural, and historical resources. 

BLM Publication Index Number: BLM/WY/PL-12/034+1330 
RECORD OF DECISION 

for the 

LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

BLM Publication Index Number: BLM/WY/PL-12/034+1330 

October 2012 

Prepared by: 

United States Department of the Interior 

Bureau of Land Management 

Rawlins Field Office 

1300 N. Third Street 

PO Box 2407 

Rawlins, WY 82301 

Cooperating Agencies: 

State of Wyoming and its Agencies 

Carbon County Commissioners 

Sweetwater County Commissioners
RECORD OF DECISION

ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT i 

October 2012

Table of Contents 

Summary ................................................................................................................ iv

1.0 Introduction ..................................................................................................1

2.0 Decision .......................................................................................................4

3.0 Management Considerations ........................................................................4

4.0 Proposed Action and Alternatives .............................................................10

4.1 Proposed Action ..................................................................................... 10

4.2 Alternatives Evaluated in Detail ............................................................ 11

4.2.1 No Action Alternative ..................................................................... 11

4.2.2 Alternative of Not Fencing the Pattern Areas ................................. 11

4.2.3 Drying Yellowcake On-Site Alternative ......................................... 12

4.3 Preferred Alternative .............................................................................. 12

4.4 Environmentally Preferred Alternative .................................................. 13

4.5 Alternatives Considered but Eliminated from Detailed Analysis .......... 13

5.0 Environmental Protection Measures and Monitoring ................................14

5.1 Agency-Required Measures ................................................................... 14

5.2 Additional Measures .............................................................................. 14

6.0 Public Involvement and Agency Consultation and Coordination..............29

7.0 Appeal of Decision ....................................................................................30

7.1 Request for Stay ..................................................................................... 31

8.0 References ..................................................................................................33

List of Figures 

Figure 1 Regional Map of the Permit Area ......................................................... 2

Figure 2 Site Layout ............................................................................................ 3

List of Tables 

Table 1 List of Regulatory Requirements .......................................................... 6

Table 2 Cross -References to Discussions of Environmental Protection 

Measures, Monitoring, and Impacts in WDEQ-LQD and NRC 

Documents .......................................................................................... 15

Table 3 Project Monitoring .............................................................................. 22

Table 4 Additional Measures ........................................................................... 27

List of Appendices 

Appendix A Updates and Errata to the Final Environmental Impact Statement 

Appendix B Responses to Comments and Compilation of Comments Received 

for the Lost Creek Uranium In-Situ Recovery Project FEIS 
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ii ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

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Acronyms and Abbreviations 

AQD Air Quality Division 

BCA Biodiversity Conservation Alliance 

BLM Bureau of Land Management 

BMP Best Management Practice 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

DDCT Density Disturbance Calculation Tool 

DEIS Draft Environmental Impact Statement 

DOI Department of the Interior 

EIS Environmental Impact Statement 

EO Executive Order 

EPA Environmental Protection Agency 

EPACT Energy Policy Act 

EQC Environmental Quality Council 

FEIS Final Environmental Impact Statement 

FLPMA Federal Land Policy and Management Act 

FR Federal Register

GEIS Generic Environmental Impact Statement 

HEA Habitat Equivalency Analysis 

IBLA Interior Board of Land Appeals 

IM Instruction Memorandum 

ISL In-Situ Leach 

ISR In-Situ Recovery 

LCI Lost Creek ISR, LLC 

LQD Land Quality Division 

MIT Mechanical Integrity Test 

NEPA National Environmental Policy Act 

NESHAP National Emissions Standards for Hazardous Air Pollutants 

NOA Notice of Availability 

NOI Notice of Intent 

NRC Nuclear Regulatory Commission 

Permit Area Lost Creek Permit Area 

PIAA project impact analysis area 

Plant the processing facilities 

PLSS Public Land Survey System 

Project Lost Creek Uranium In-Situ Recovery Project 

RMP Resource Management Plan 

ROD Record of Decision 

SEIS Supplemental Environmental Impact Statement 

SER Safety Evaluation Report 

SGIT Sage Grouse Implementation Team 

SHPO State Historic Preservation Office 

SWCBCC Sweetwater County Board of County Commissioners 

SWPPP Storm Water Pollution Prevention Plan 
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ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT iii 

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TAC Technical Advisory Committee 

UIC Underground Injection Control 

URL Uniform Resource Locator 

U.S. United States 

USC United States Code 

USFWS United States Fish and Wildlife Service 

USGS Unites States Geological Survey 

WDEQ Wyoming Department of Environmental Quality 

WDEQ-AQD Wyoming Department of Environmental Quality-Air Quality 

Division 

WDEQ-LQD Wyoming Department of Environmental Quality-Land Quality 

Division 

WGFD Wyoming Game and Fish Department 

WOC Wyoming Outdoor Council 

WQD Water Quality Division 

WSEO Wyoming State Engineer's Office 

WYPDES Wyoming Pollutant Discharge Elimination System 

 
RECORD OF DECISION

iv ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

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Summary 

Pursuant to Title 43 of the United States (U.S.) Code of Federal Regulations 

(CFR) Subpart 3809, which applies to operations authorized by mining laws on 

public lands, Lost Creek ISR, LLC (LCI) submitted a Plan of Operations to the 

Bureau of Land Management (BLM) in November 2009. LCI is proposing the 

construction, commercial operation, and reclamation of facilities for the Lost 

Creek Uranium In-Situ Recovery Project (Project) in Sweetwater County, 

Wyoming. Planned facilities include well pads for injection, production and 

monitoring, wellhead houses, a central processing facility, an access road network 

and pipeline system. Approximately 345 acres of actual surface disturbance is 

expected within the approximately 4,250-acre project boundary, with most of the 

surface disturbance related to construction of the well fields used to extract the 

uranium from the site. 

The Lost Creek Uranium In-Situ Recovery Project Environmental Impact 

Statement (EIS) analyzed the proposed development and recovery of uranium by 

the in situ mining process where a solution is injected into a well to dissolve the 

mineral, then the solution bearing mineral is pumped back to the surface for 

processing. The EIS disclosed to the public the direct, indirect, and cumulative 

environmental impacts of authorizing the proposal. Comments received following 

the issue of the Final Environmental Impact Statement (FEIS) have been 

addressed in this Record of Decision (ROD). 

The BLM High Desert District Manager selects the Agency-Preferred Alternative 

(the Proposed Action with Drying Yellowcake On-Site). The BLM has 

determined that implementation of this Decision, with the specified environmental 

protection measures and monitoring, will allow LCI to mine a valuable uranium 

deposit under the authority of the U.S. 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 BLM has worked closely with the other permitting agencies. The Nuclear 

Regulatory Commission (NRC) issued LCI a license in August 2011. The 

Wyoming Department of Environmental Quality (WDEQ) issued the project a 

permit in October 2011. 
RECORD OF DECISION

ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 1 

October 2012

1.0 Introduction

This ROD summarizes the BLM’s decision regarding the Project and provides the 

justification for the decision, per the requirements of NEPA. An EIS was 

prepared in compliance with NEPA, as amended (42 United States Code [USC] 

4321 et seq.), and its implementing regulations found in 40 CFR Parts 1500 to 

1508. The BLM issued the DEIS on April 27, 2012 and the FEIS on August 17, 

2012. 

LCI is proposing the construction, commercial operation, and reclamation of 

facilities for In-Situ Recovery (ISR) operations within the Lost Creek Permit Area 

(Permit Area). ISR involves the use of a recovery solution, known as a lixiviant, 

to extract the mineral from the geologic formation without physically removing 

the ore-bearing strata, and the mineral is removed from the solution using ion 

exchange resins at the processing facility (the Plant). Under the Proposed Action, 

about six million pounds of uranium will be produced from the Permit Area. The 

Proposed Action will extend over a 12-year period, including about seven months 

for initial construction, seven years for production, and the remaining time for 

final reclamation. 

Eighty-five percent of the Permit Area is public land (Figure 1) managed by the 

BLM Rawlins and Lander Field Offices. The remaining 15 percent of the Permit 

Area is owned by the State of Wyoming and subject to state mineral lease. The 

Permit area is located in Township 25 North and Ranges 92 and 93 West, and 

encompasses a total of 4,254 acres of land. Under the Proposed Action, the 

projected surface disturbance is about 345 acres, and the majority of the Project’s 

activities will be on public land. The proposed facilities include: mine units; 

improved and newly constructed roads; the Plant, office, and associated 

structures; pipelines and transmission lines; and equipment for air and water 

quality monitoring. Figure 2 maps the facilities associated with the Project. 

The BLM’s decision is presented in Section 2, and management considerations 

are summarized in Section 3. The Proposed Action for the Project and the 

alternatives are discussed in Section 4, where the BLM also specifies its Preferred 

Alternative. Environmental protection measures and monitoring are summarized 

in Section 5. Section 6 discusses the public and agency consultation that the 

BLM conducted during the NEPA process. A list of errata, or corrections, from 

the FEIS is included in Appendix A. 

 
2 ROD 

– LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

October 2012
ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 3 

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RECORD OF DECISION

4 ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

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2.0 Decision

The decision of the District Manager, BLM High Desert District, is to select the 

Preferred Alternative, which is the Proposed Action (Section 4.1) with Drying 

Yellowcake On-Site (Section 4.2.3 and 4.3) inclusive of the required 

environmental protection measures and monitoring (Section 5). The Decision is 

based on the final Plan of Operations submitted to the BLM November 2009 

pursuant to 43 CFR 3809 and 3715, and the analysis in the FEIS and NRC SEIS. 

Development of the Project is authorized by this Decision subject to compliance 

with all pertinent federal, state, and local laws or requirements. 

3.0 Management Considerations

In making the decision to approve the Preferred Alternative, described in Section 

3.5, the BLM has carefully considered the following factors: 

x The Preferred Alternative is the alternative that best fulfills the agency’s 

statutory mission and responsibilities, considering economic, 

environmental, technical, and other factors. 

x Other federal, state, and local agencies have jurisdiction (including 

inspection responsibilities) over certain aspects of the Proposed Action. 

Table 1 lists additional federal, state, and local permits, policies, and 

actions that have been or will need to be approved as a part of this Project. 

x Tables 2, 3, and 4 summarize the environmental protection measures and 

monitoring which will be implemented in accordance with the various 

agency requirements and guidance. 

x Implementation of this Decision will not cause unnecessary or undue 

degradation of the public lands and is consistent with other legal 

requirements. 

x Resource Management Plan Conformance: This decision is in 

conformance with the Rawlins Resource Management Plan (December 

2008), Lander Resource Management Plan (June 1987), the 43 CFR 3809 

regulations, and the 1872 Mining Law, as amended. 

x The Decision conforms to the new Council on Environmental Quality 

(CEQ) guidance in that: the Proponent has committed to the 

environmental protection measures; monitoring will be performed and the 

results will be available to the public; and effectiveness of environmental 

protection measures will be considered and revisited through mechanisms 

such as the required Annual Reports (covering a broad range of resources) 

to the agencies and the Adaptive Management Program (more specific to 

wildlife as described in Section 4.9.1.10 of the FEIS). 

x Per the provisions of the Federal Land Policy and Management Act 

(FLPMA), public lands are to be managed in accordance with the balance 

of several considerations including “in a manner that will protect the 

quality of scientific, scenic, historical, ecological, environmental, air and 
RECORD OF DECISION

ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 5 

October 2012

atmospheric, water resource, and archeological values” and “in a manner 

which recognizes the Nation’s need for domestic sources of minerals”

(FLPMA, Sec. 102((8) and (12)). The Decision is in accordance with this 

mandate. 

x The Preferred Alternative is consistent with the Governor’s Executive 

Order (EO 2011-5) for the protection of Greater Sage-Grouse, as 

supported by the EQC hearing, conducted as part of the WDEQ-LQD 

permitting process (Wyoming EQC, 2011) and the letter of July 18, 2012 

from Mathew H. Mead, Governor of Wyoming, to Dennis J. Carpenter, 

BLM Rawlins Office Field Manager (Appendix B). 

x The Preferred Alternative will help maintain revenue for local government 

and generate full-time and contract positions. 

x A reclamation bond to provide for reclamation of both private and public 

lands will continue to be required and regularly reviewed and updated in 

compliance with both the 43 CFR 3809 regulations and the requirements 

of the NRC and the Wyoming Department Environment Quality-Lands 

Quality Division (WDEQ-LQD). 

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

(EPACT 2005) signed into law on August 8, 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.” In addition to providing this direction, 

the EPACT 2005 provides significant incentives for the continuation and 

expansion of nuclear power in the U.S. (U.S. Congress, 2005).

x Since the publication of the EIS, LCI has indicated intent to develop the 

Lost Creek East Area. Because LCI has not prepared or submitted a 

proposed plan modification to BLM, there is insufficient information to 

address this expansion in the FEIS, as the development extent is 

speculative at this time. This ROD does not make any decision on 

activities pursuant to this or any other amendment to the LCI NRC license. 

Any development activity in this area will be covered by a separate NEPA 

analysis and decision. Development of the Lost Creek East Area was 

appropriately considered in the Cumulative Effects section of the FEIS. 

 
RECORD OF DECISION

6 ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

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Table 1 List of Regulatory Requirements (Page 1 of 4) 

PERMIT OR 

LICENSE STATUS COMMENTS 

Federal

NRC, Source 

and Byproduct 

Material License 

License issued August 2011. License No. SUA-1598, Docket No. 40-9068. 

Uniform Resource Locator (URL): 

http://adams.nrc.gov/wba/ 

Under Advanced Search, Document Properties, Accession Number 

ML111940049 

License amendment to operate 

Mine Unit 1 submitted 

September 2011. 

 Under review by NRC. 

URL: 

http://pbadupws.nrc.gov/docs/ML1220/ML12202B115.html 

License amendment to operate 

a vacuum dryer submitted 

January 2012. 

 Under review by NRC. 

URL: 

http://pbadupws.nrc.gov/docs/ML1204/ML120470355.html 

NRC, Safety 

Evaluation 

Report (SER) 

Final SER issued August 

2011. 

License No. SUA-1598, Docket No. 40-9068. 

URL: 

http://adams.nrc.gov/wba/ 

Under Advanced Search, Document Properties, Accession Number 

ML112231724 

NRC, NEPA 

Review

Final SEIS issued June 2011. NUREG-1910, Supplement 3. 

URL: 

http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1910/s3/ 

EPA, UIC Class 

I & Class III 

Wells 

-- See WDEQ permits as WDEQ-Water Quality 

Division (WQD) has primacy for Class I wells 

and WDEQ-LQD has primacy for Class III 

wells. 

EPA, Aquifer 

Reclassification 

Approved August 2011. The aquifer exemption covers each mine unit 

plus 120 feet beyond the monitoring well ring 

for each mine unit. 

EPA, 

Construction 

Application for 

the Storage 

Ponds

Approved December 2011. For compliance with 40 CFR 61.252 (b)(1) & 40 

CFR 192.32(a) as required by 40 CFR 61.252 (c).

URL: http://www.epa.gov/region8/air/LostCreekNESHAP_ApprovalDec2011.pdf 

BLM, Plan of 

Operations Submitted November 2009. Basis for the EIS.
RECORD OF DECISION

ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 7 

October 2012

Table 1 List of Regulatory Requirements (Page 2 of 4) 

PERMIT OR 

LICENSE STATUS COMMENTS

State 

WDEQ-LQD, 

Permit to Mine 

Issued October 2011. Permit No. 788. As WDEQ-LQD has 

primacy for UIC Class III wells, the Permit 

Posted to the BLM Rawlins Field Office Lost Creek Uranium In-Situ

Recovery Project website, URL: 

http://www.blm.gov/wy/st/en/info/NEPA/documents/rfo/lostcreek.html 

WDEQ - Air 

Quality Division 

(AQD), Air 

Quality Permit 

Issued January 2010. Permit No. CT-7896. 

URL: http://pbadupws.nrc.gov/docs/ML1034/ML103480375.pdf 

WDEQ-WQD, 

UIC Class I 

Wells 

Issued May 2010. Permit No. 09-586. 

URL: http://deq.state.wy.us/wqd/events/public%20notices/UIC/ 

FinalPermit_UREnergy_ClassI_09-586_LostCreekISR%20(2).pdf 

WDEQ-WQD, 

General Permit to 

Discharge Storm 

Water Associated 

with Large

Construction 

Activity Under the 

Wyoming Pollutant 

Discharge 

Elimination System 

(WYPDES) 

Program 

Approved per Permit 

Authorization Number 

WYR103695. 

Storm Water Pollution Prevention Plan 

(SWPPP) required per General Permits. 

WDEQ-WQD, 

General 

Authorization to 

Discharge Storm 

Water Associated 

with Mineral 

Mining Activities 

Under WYPDES 

Application will be 

submitted once WDEQLQD Permit to Mine 

approved. 

Wyoming State 

Engineer’s Office 

(WSEO), Permit 

to Appropriate 

Groundwater 

Submitted for wells 

completed to date; will 

be submitted for future 

wells.

-- 
RECORD OF DECISION

8 ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

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Table 1 List of Regulatory Requirements (Page 3 of 4) 

PERMIT OR 

LICENSE STATUS COMMENTS 

State (cont’d)

WSEO, Permit 

for Storage 

Ponds 

Approved May 

2010.

Permit No. 13595R. 

Wyoming Game 

and Fish 

Department 

(WGFD), 

Wildlife 

Monitoring and 

Protection Plan 

Approved. 

Approval required as part of WDEQ-LQD 

Permit to Mine.

County

Sweetwater 

County Planning 

Commission, 

County 

Development 

Plan 

Conditionally 

Approved 

December 2009 

Must meet Development Plan Conditions 

required as required by Resolution 09-12-ZO01

Sweetwater 

County Health 

Department, 

Septic System 

Submitted June 29, 

2009. 

Sweetwater Health Department Septic Tank 

Permit approved by Permit 11-82 on April 14, 

2011.

Sweetwater 

County Public 

Works Director, 

Road Use and 

Maintenance 

Agreement 

If not already done 

prior to BLM 

approval of 

proposed action, 

LCI will prepare 

and submit.

Sweetwater County Board of County 

Commissioners and the Sweetwater County 

Public Works Department, as of September 11, 

2012, have not received a draft of said Road 

Use and Maintenance Agreement

Sweetwater 

County 

Department of 

Engineering, 

County Road 

Crossing and 

Access Permits or 

Licenses 

 
RECORD OF DECISION

ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 9 

October 2012

Table 1 List of Regulatory Requirements (Page 4 of 4) 

PERMIT OR 

LICENSE STATUS COMMENTS 

County (cont’d)

Sweetwater 

County 

Emergency 

Management 

Hazmat 

Inventory 

Provide outstanding 

items as required by 

the Conditional 

Development Plan 

approval. 

Required by Federal Tier II Regulations.

International Fire 

Code 

Compliance 

Current 

coordination with 

SWCO 

Per Resolution 09-12-ZO-01 

Sweetwater 

County Weed 

and Pest

Coordination 

recommended 

during construction 

and operation

Noxious and invasive weed control 

coordination.

Contact: Gale Lamb, Supervisor 

Sweetwater County Weed and Pest District, 

307-874-6107 

 
RECORD OF DECISION

10 ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

October 2012

4.0 Proposed Action and Alternatives

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. The analysis in the EIS included the Proposed Action, three 

alternatives evaluated in detail, and eight alternatives considered, but eliminated 

from detailed study. The EIS incorporates by reference the WDEQ Permit to 

Mine (LCI, 2011b) and the NRC SEIS (NRC, 2011a), and builds off of the 

analyses presented in these documents. 

NEPA requires evaluation of a No Action Alternative and reasonable alternatives 

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

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

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

12 years. The two alternatives that were considered and evaluated in detail 

include the Not Fencing the Pattern Areas and the Drying Yellowcake On-Site. 

4.1 Proposed Action 

The Proposed uranium ISR operation will extract the mineral from permeable, 

uranium-bearing sandstones through a series of mine units. During operations, a 

lixiviant will be pumped into the ground which oxidizes the uranium mineral, 

allowing dissolution of uranium in groundwater. The resulting uranium-laden 

solution will then be pumped from the production wells in the mine unit(s) 

through buried pipelines to the Plant. There, the uranium will be 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 will be 

regenerated and pumped back to the mine unit(s) to recover additional uranium. 

Storage ponds will be used in conjunction with Underground Injection Control 

(UIC) Class I wells for waste water disposal. After mining, groundwater 

restoration will essentially reverse the effects of oxidation to re-establish the 

reducing conditions that were present prior to mining. 

For the purposes of the 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 within each 

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

however, because of the progressive development of the mine units, there will be 

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) 
RECORD OF DECISION

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October 2012

x Reclamation 

o Mine Unit Restoration and Reclamation 

o Final Reclamation 

Initial Construction will occur during the first year of the Project and includes the 

major facility construction, 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 will take about two years, will 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 

will begin during production of the previous mine unit. 

Mine Unit Restoration and Reclamation will begin when technical, economic, and 

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

Restoration and reclamation of each mine unit includes groundwater restoration, 

radiological decontamination, equipment removal/decommissioning (e.g., well 

abandonment), and surface reclamation (e.g., well site reseeding). 

Final Reclamation, including facility decontamination and decommissioning and 

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

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

success will be required until at the least the fifth full growing season. 

4.2 Alternatives Evaluated in Detail 

As mentioned above, three alternatives were evaluated in detail: No Action; Not 

Fencing the Pattern Areas; and Drying Yellowcake On-Site. These alternatives 

are described below. 

4.2.1 No Action Alternative 

The No Action Alternative describes what would likely happen to the Permit 

Area, should the Project not be implemented. Current land uses 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. 

4.2.2 Alternative of Not Fencing the Pattern Areas 

An alternative option to the Proposed Action is Not Fencing the Pattern Areas. If 

the pattern areas were fenced, grazing would not be possible in the pattern areas. 
RECORD OF DECISION

12 ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

October 2012

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

the pattern area and were startled. However, not fencing the pattern areas leaves 

the well heads exposed, which could then be damaged by cattle or wild horses and 

result in potential spills or leaks of the lixiviant solution. The fencing also would 

increase security and safety of the site and would be beneficial to the reclamation 

of the areas within the fences. Therefore, the alternative of ‘Not Fencing the 

Pattern Areas’ was evaluated in detail. It should be noted that 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. This alternative is discussed in detail in 

Section 2.3.1.2 of the FEIS. 

4.2.3 Drying Yellowcake On-Site Alternative 

This alternative is the same as the Proposed Action with the addition of a 

yellowcake drying and 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 filter-pressed 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. 

Historically, vacuum drying of yellowcake in ISR has resulted in no measurable 

emissions to the environment, because the vacuum system is designed to prevent 

any releases (NRC, 2011). 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. 

4.3 Preferred Alternative 

The BLM’s Preferred Alternative is the alternative which the BLM believes will 

fulfill its statutory mission and responsibilities, giving consideration to economic, 

environmental, technical and other factors, as outlined in Section 101 of the 

NEPA. The BLM selects the Drying Yellowcake On-Site Alternative as the 

Preferred Alternative for this Project. This alternative is the same as the Proposed 

Action, but rather than shipping the slurry off-site for processing, the slurry will 

be dried on-site and shipped from the site as yellowcake uranium. This action 

involves drying the mineral solution into a solid yellowcake form within the plant. 

Housing the drying-packing facility within the processing plant will reduce 

shipments from the site, resulting in fewer transportation-related impacts, wildlife 
RECORD OF DECISION

ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 13 

October 2012

disturbances, and air quality impacts. Not Fencing the Pattern Area was not 

chosen as a preferred alternative due to the nature of the potential impacts and the 

benefits associated with having the areas fenced. Although the fencing will 

restrict grazing land, the potential leaks and spills from damaged wellheads pose a 

more significant impact to the environment. Additionally, the benefits of fencing 

the pattern areas, including safety and reclamation advantages, outweigh the 

potential impacts of eliminating a small portion of grazing land in the area. 

4.4 Environmentally Preferred Alternative 

The environmentally preferred alternative is the No Action Alternative, as it 

would have the least impact on the environment, wildlife, and current uses of the 

land. However, the BLM believes that the benefits to the local economy and the 

management considerations described above in Section 3 would outweigh the 

limited impacts to the environment, particularly when considering the 

environmental protection measures that would be implemented as part of the 

Proposed Action. 

4.5 Alternatives Considered but Eliminated from Detailed 

Analysis 

In addition to the alternatives evaluated in detail, several alternatives were 

considered, but eliminated from detailed study. These alternatives are listed 

below, along with the primary reason(s) for elimination. Several were eliminated 

based on the analyses presented in other documents, such as the NRC SEIS 

(2011a) and WDEQ-LQD Permit to Mine (LCI, 2011b). 

x Portable Drill Pits and Closed Loop Drilling Systems – Limited or 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 ) – Significantly greater surface disturbance 

(with corresponding increases in soil, vegetation, and wildlife 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 – Suggested either fewer mine units 

or adjusting the schedule to attempt to minimize impacts while still 

accomplishing the same goal. 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 site 
RECORD OF DECISION

14 ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

October 2012

conditions restrict use of alternative lixiviant types because the 

alternatives available create a groundwater environment that is difficult to 

restore to its previous state; 

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 increased potential impacts to 

active raptor nests; and 

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

evaluated by the NRC, WDEQ-LQD, and WGFD [LCI, 2011a]) –

Increased surface disturbance (with corresponding increases in vegetation, 

soil, surface water, and wildlife impacts). 

5.0 Environmental Protection Measures and 

Monitoring

5.1 Agency-Required Measures 

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

the applicable environmental statutory and regulatory programs have developed 

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

Agency-required mitigation measures are summarized in Table 2. LCI will also 

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 WDEQAQD, the WDEQ-LQD, and the NRC. The monitoring measures are summarized 

in Table 3. 

5.2 Additional Measures 

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

Mining Law, the 43 CFR 3809 regulations, and the Rawlins Resource 

Management Plan (RMP) (BLM, 2008) and the Lander Resource Management 

Plan (BLM, 1987). Based on the BLM’s review and on comments received 

during the NEPA process (comments and responses can be found in Appendix F 

in the FEIS), some additional measures will be needed to address concerns not 

previously addressed through the other processes. These concerns are related to 

disturbances near ephemeral drainages, groundwater stability, impacts to visual 

resources, and several concerns associated with wildlife. The measures to address 

these concerns are listed in Table 4.
REC

ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

October 2012

Table 2 Cross -References to Discussions of Environmental Protection Measures, Monitoring, an

LQD and NRC Documents (Page 1 of 7) 

Agency 

BLM 

WDEQ-LQD 

Permit No. 788 

NRC 

Environ

EIS SEIS 

License 

No. 

SUA-1598 

Proposed 

Action, 

Protection 

Measures & 

Monitoring 

Impacts 

Proposed Action, 

Protection Measures 

& Monitoring

Impacts 

Land Use Baseline § 3.1 -- Appendices D1 & D2 § 3.2 -- 

-- 

Determined histori(e.g., grazing, type

Construction §§ 2.1.3.2, 2.1.5, 

2.3.1, 4.2.1 & 

4.2.2 § 4.2.4 

§ OP 2.3 -- 

§ 4.2.1.1 

Limit disturbance 

Operation § 4.2.1.2 Reclamation

§§ 2.1.2.5, 

2.1.2.6, 4.2.1 & 

4.2.2 

§ RP 4.5.1 § 2.1.1.1.5 §§ 4.2.1.3 & 4.2.1.4 Groundwater resto

approved post-minuses) as soon as po

Transportation Baseline § 3.2 -- -- § 3.3 -- 

-- 

Determined status 

Construction §§ 2.1.2.5, 2.3.1, 

4.3.1, 4.3.2 & 

4.3.5 

§§ 4.3.4.1 

& 4.3.5 § OP 2.6 §§ 2.1.1.1.2.3 & 2.1.1.1.7 

§§ 4.3.1.1 & 

4.3.2.1 Proper road install

safety training & i

Operation monitoring. §§ 4.3.4.2 & 4.3.5 §§ 4.3.1.2 & 4.3.2.2 Reclamation §§ 2.1.5, 2.3.1, 4.3.1.3 & 4.3.5 §§ 4.3.4.3 & 4.3.5 §§ RP 3.2 & RP 4.4 §§ 2.1.1.1.5.4 & 2.1.1.1.7 §§ 4.3.1.3, 4.3.1.4, 4.3.2.3 & 4.3.2.4 Unless otherwise a

reclaimed. Improvremoved. 

Geology, Ore Mineralogy, & Seismology Baseline § 3.3 -- Appendix D5 § 3.4.1 & 3.4.3 -- -- 

Assessed stratigrapseismology, thickn

historic drilling locmine unit before st

Construction

§§ 2.1.3, 2.3.1, 

4.4.1, 4.4.2 & 

4.4.5 

§§ 4.4.4.1 & 

4.4.5

§ OP 3.3 

§§ 2.1.1.1.2.4.1 

- 2.1.1.1.2.4.3

§§ 4.4.1.1, 

4.4.2 & 4.4.3 

Condition 

10.5

Continued efforts tstatus, & properly installation in acco

Operation Update geologic in

§§ 2.1.4.1, 

2.1.4.3, 2.3.1, 

4.4.1, 4.4.2 & 

4.4.5 

§§ 4.4.4.2 & 

4.4.5

§§2.1.1.1.2.4.3

§§ 4.4.1.2, 

4.4.2 & 4.4.3 

Reclamation

§§ 2.1.5.1, 2.3.1, 

4.4.1, 4.4.2 & 

4.4.5 

§§ 4.4.4.3 & 

4.4.5 § RP 3.1 

§ 4.4.1.3, 

4.4.1.4, 

4.4.2 & 4.4.3 

-- 

Abandon drill holeapplicable permits 
RECORD OF DECISION

16 ROD – LOST CREEK URANIUM IN-SITU 

Table 2 Cross-References to Discussions of Environmental Protection Measures, Monitoring, and 

LQD and NRC Documents (Page 2 of 7) 

Agency

BLM

WDEQ-LQD 

Permit No. 788

NRC

Summary of Envi

EIS SEIS

License 

No. 

SUA-1598

Proposed 

Action, 

Protection 

Measures & 

Monitoring 

Impacts

Proposed Action, Protection Measures & Monitoring

Impacts

SoilsBaseline § 3.4 -- 

Appendix D5, 

Attachments 

OP-5a & b 

§ 3.4.2 -- -- 

Evaluated soil type& determined topsof each mine unit b

Construction

§§ 2.1.2.3, 

2.1.3.2, 2.3.1, 

4.5.1, 4.5.2 & 

4.5.5 

§§ 4.5.4.1 & 

4.5.5 § OP 2.5 § 2.1.1.1.2.1 §§ 4.4.1.1, 4.4.2 & 4.4.3 

Condition 

11.6

Minimize soil distusoil removal necessoils. Implement pleaks to reduce chaplace to address anreleases. Operation

§§ 2.1.2.5, 

2.1.4.3, 2.3.1, 

4.5.1, 4.5.2 & 

4.5.5 

§§ 4.5.4.2 & 

4.5.5

§§ OP 2.5 & OP 

3.5 

§§ 2.1.1.1.4.4 & 

2.1.1.1.4.5 

§ 4.4.1.2, 

4.4.2 & 4.4.3 

Reclamation

§§ 2.1.5, 2.3.1, 

4.5.1, 4.5.2 & 

4.5.5 

§§ 4.5.4.3 & 

4.5.5

§§ RP 3.3 & 

RP 4.5 § 2.1.1.1.5 

§ 4.4.1.3, 

4.4.1.4, 

4.4.2 & 4.4.3 

Conditions 

11.6 & 

12.13 

Recontour if neces

Prepare surface for 

Surface Waters, Wetlands, & Aquatic Ecology Baseline § 3.5 -- Appendices D6 & D11 §§ 3.5.1 & 3.6.2 -- -- 

Mapped drainagesMeasured flows if 

samples for assessmpermanent surface exist in the Project 

Construction

§§ 4.6.1, 4.6.2 & 

4.6.5 §§ 4.6.4 

§§ OP 2.9, OP 2.11.1, 

OP 3.5 & 

Attachments OP-2 

& OP-4 

§§ 6.2.2, 6.2.4, 6.3.2 

& 6.3.3 

§§ 4.5.1.1.1, 

4.5.1.2, 4.51.3 

& 4.6.1.1.3 

Condition 

11.6

Limit disturbance wfor ephemeral draiImplement protectireduce chance of sin place to address releases. 

Operation

§§ 4.5.1.1.2, 

4.5.1.2 & 

4.5.1.3 

Reclamation §§ RP 3.2 & RP 4.0 -- 

§§ 4.5.1.1.3, 

4.5.1.1.4, 

4.5.1.2 & 

4.51.3 

Progressive reclamRemoval of road cincluding recontoureplacement, & rev
REC

ROD 

– LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

October 2012

Table 2 Cross-References to Discussions of Environmental Protection Measures, Monitoring, and 

LQD and NRC Documents (Page 3 of 7) 

Agency

BLM

WDEQ-LQD 

Permit No. 788

NRC

Summary of En

EIS SEIS

License 

No. 

SUA-1598

Proposed 

Action, 

Protection 

Measures & 

Monitoring

Impacts

Proposed Action, 

Protection Measures 

& Monitoring

Impacts

Groundwater Baseline § 3.6 -- Appendix D6 & § OP 3.6.4.1 § 3.5.2 -- 

Conditions 

10.9 

through 

10.12, & 

11.3 

Determined aquifeinformation & aquuses. Collected grevaluation of each 

Construction

§§ 2.1.2.2 

through 2.1.2.4, 

2.3.1, 2.1.3.2, 

4.7.1, 4.7.2, 

4.7.4 & 4.7.8 

§§ 4.7.4 & 

4.7.5

§§ OP 2.9, OP 2.11.2, 

OP 3.0 & 

Attachments 

OP-2, OP-7 & 

OP-8 

§§ 2.1.1.1.2.4.1 

- 2.1.1.1.2.4.3, 6.2.5, 

6.3.1, & 6.3.2

§§ 4.5.2.1.1, 

4.5.2.2, & 

4.5.2.3

Conditions 

10.5, 11.6, 

12.4 & 

12.15

Proper well construMechanical Integripipelines, storage pdetection measuresinspection. Routinquality sampling & process performanaccordance with apaddress detections anomalous conditi

Operation

§§ 2.1.4.1, 

2.1.4.3, 2.3.1, 

4.7.1, 4.7.2, 

4.7.4 & 4.7.8 

§§ 4.7.4 & 

4.7.6

§§ 2.1.1.1.3.1.1 

- 2.1.1.1.3.1.3, 6.2.5, 

6.3.1 & 6.3.2 

§ 4.5.2.1.2, 

4.5.2.2 & 

4.5.2.3

Conditions 

10.1, 10.5, 

10.7 

through 

10.9, 10.13, 

11.1, 11.4 

through 

11.6 & 12.7 

Reclamation

§§ 2.1.5.1, 2.3.1, 

4.7.1, 4.7.2, 

4.7.4 & 4.7.8 

§§ 4.7.4 & 

4.7.7

§§ RP 1.0 & 

RP 2.0 

§§ 2.1.1.1.4, 6.2.5 & 

6.3.1 

§§ 4.5.2.1.3, 

4.5.2.1.4, 

4.5.2.2 &

 4.5.2.3

Condition 

10.6

Mine Units - Prograccordance with apreverse osmosis, trincluding during a returned to the useISR. All Wells - Aapplicable permits 

Vegetation Baseline § 3.7 -- Appendix D8 § 4.3.4.1 -- 

-- 

Mapped vegetation diversity & assesse

Construction §§ 2.1.3, 2.3.1, 

4.8.1, 4.8.2 & 

4.8.5 

§ 4.8.4.1 

§ OP 2.7 

§ 2.1.1.1.2.1 §§ 4.6.1.1.1.1, 4.6.2 & 4.6.3 Limit disturbance w

Sagebrush. Weed c

Operation § 4.8.4.2 §§ 6.2.3 & 6.5.1 after installation, w

§§ 4.6.1.2.1, 4.6.2 & 4.6.3 

Reclamation

§§ 2.1.5, 2.3.1, 

4.8.1, 4.8.2 & 

4.8.5 

§ 4.8.4.3 § RP 4.5 §§ 2.1.1.1.5.5 & 6.5.1 §§ 4.6.1.3, 4.6.1.4, 4.6.2 & 4.6.3 Progressive revege

facility removal in Vegetation samplin
RECORD OF DECISION

18 ROD 

– LOST CREEK URANIUM IN-SITU 

Table 2 Cross-References to Discussions of Environmental Protection Measures, Monitoring, and 

LQD and NRC Documents (Page 4 of 7) 

Agency

BLM

WDEQ-LQD 

Permit No. 788

NRC

Summary o

EIS SEIS

License 

No. 

SUA-1598

Proposed Action, 

Protection 

Measures & 

Monitoring

Impacts

Proposed Action, 

Protection Measures 

& Monitoring

Impacts

Wildlife Baseline § 3.8 -- Appendix D9 §§ 3.2.1, 3.6.1.2 & 3.6.3 -- 

-- 

Surveyed specareas for Grea

Construction §§ 2.1.2.6, 2.3.1, 4.9.1, 4.9.2 & 4.9.5 §§ 4.9.5 

§ OP 2.7 & 

Attachment OP-6 

§§ 2.1.1.1.2.5, 6.2.3, 6.5.2 & Appendix F 

§§ 4.6.1.1.1.2, 

4.6.1.1.2, 4.6.1.1.4, 

4.6.1.1.5, 4.6.2 

& 4.6.3 

Implement Beminimize distperch & collisstipulations dFence construrequirements. Adaptive Man

Operation §§ 2.3.1, 4.9.1, 4.9.2 & 4.9.5 §§ 4.9.6 §§ 6.2.3, 6.5.2 & Appendix F §§ 4.6.1.2.2, 4.6.2 & 4.6.3 Reclamation §§ 2.1.5, 2.3.1, 4.9.1, 4.9.2 & 4.9.5 §§ 4.9.7 §§ 6.2.3, 6.5.2 & Appendix F §§ 4.6.1.3, 4.6.1.4, 4.6.2 & 4.6.3 Continue use 

during reclamSurface reclam

control, for ha

Wild Horses Baseline § 3.9 -- Appendix D9 §§ 3.2.1 & 3.6.1.2.7 -- 

-- 

Noted occurre

Construction §§ 2.1.2.6, 2.1.3, 4.10.1 & 4.10.2 §§ 4.10.4.1 & 4.10.5 § OP 2.8 & 

Attachment OP-6 

§ 2.1.1.1.2.5 §§ 4.2.1.1 & 4.6.1.1.1.2 Implement BM

construction irequirements. 

under gates. Operation §§ 4.10.1 & 4.10.2 §§ 4.10.4.2 & 4.10.5 

-- 

§ 4.2.1.2 

Reclamation §§ 2.1.2.6, 2.1.5, 4.10.1 & 4.10.2 §§ 4.10.4.3 & 4.10.5 §§ RP 4.5.4 & 4.5.5 -- Continue use 

facility removrevegetation & 

Meteorology, Climatology, & Air Quality Baseline § 3.10 -- Appendix D4 § 3.7 -- Condition 12.8 Installed mete

particulates. 

Construction

§§ 2.1.1.4, 2.1.3, 

4.11.1 & 4.11.2 

§§ 4.11.4.1, 

4.11.4.4 & 

4.11.5 

OP 5.1.1 

§§ 2.1.1.1.6.1, 

2.1.2 & 

 2.1.3 

§§ 4.7.1.1, 

4.7.3 & 4.7.3.1 

-- 

Implement BM& vehicle maemissions. In

Operation loading of the 

§§ 4.11.4.2, 

4.11.4.4 & 

4.11.5 

§§ 4.7.1.2, 

4.7.3, & 

4.7.3.2 

Reclamation

§§ 4.11.4.3, 

4.11.4.4 & 

4.11.5

§§ 4.7.1.3, 

4.7.1.4, 

4.7.3, 

4.7.3.3 & 

4.7.3.4 

Continue use 

facility remov

each mine & wind erosion.
REC

ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

October 2012

Table 2 Cross-References to Discussions of Environmental Protection Measures, Monitoring, and 

LQD and NRC Documents (Page 5 of 7) 

Agency

BLM

WDEQ-LQD 

Permit No. 788

NRC

Summary of E

EIS SEIS

License 

No. 

SUA-1598

Proposed 

Action, 

Protection 

Measures & 

Monitoring

Impacts

Proposed Action, 

Protection Measures 

& Monitoring

Impacts

Noise Baseline § 3.11 -- -- § 3.8 -- 

-- 

Measured ambiegenerated by ma

Construction

§§ 4.12.1 & 

4.12.5 

§§ 4.12.4.1 

& 4.12.5 

§ OP 2.8 -- 

§§ 4.8.1.1, 

4.8.2 & 4.8.3 

Implement BMPmaintenance & mdaylight hours.

Operation §§ 4.12.4.2 & 4.12.5 §§ 4.8.1.2, 4.8.2 & 4.8.3 Reclamation §§ 4.12.4.3 & 4.12.5 §§ 4.8.1.3, 4.8.1.4, 4.8.2 & 4.8.3 Historic & Cultural Resources Baseline § 3.12 -- Appendix D3 § 3.9 -- -- Researched histo

surveys. 

Construction

§§ 2.1.7, 2.2, 

4.13.1 & 

4.13.2 

§§ 4.13.3, 

4.13.4 & 

4.13.5

§ OP 2.4 

Appendix E §§ 4.9.1.1, 4.9.2 & 4.9.3 

Condition 

 9.8 

Avoid known si

plan at unavoida

Operation unanticipated di

-- 

§§ 4.9.1.2, 

4.9.2 & 4.9.3 

Reclamation

§§ 4.9.1.3, 

4.9.1.4, 4.9.2 

& 4.9.3 

Plan in place for archeological re

Visual & Scenic Resources Baseline § 3.13 -- 

-- 

§ 3.10 -- 

-- 

Evaluated visibiassessed viewsh

to scenic resourc

characteristics. 

Construction

§§ 2.1.2, 2.1.3, 

2.3.1, 4.14.1 & 

4.14.5 

§ 4.14.4.1 

-- 

§§ 4.10.1.1, 

4.10.2 & 

4.10.3 Minimize distur

reduce visibility

Operation §§ 2.1.2, 2.1.4, 4.14.1 & 4.14.5 § 4.14.4.2 §§ 4.10.1.2, 4.10.2 & 4.10.3 Reclamation §§ 2.1.2, 2.1.5, 4.14.1 & 4.14.5 § 4.14.4.3 

§§ 4.10.1.3, 

4.10.1.4, 

4.10.2, & 

4.10.3 

Removal of facivegetation.
RECORD OF DECISION

20 ROD – LOST CREEK URANIUM IN-SITU 

Table 2 Cross-References to Discussions of Environmental Protection Measures, Monitoring, and 

LQD and NRC Documents (Page 6 of 7) 

Agency

BLM

WDEQ-LQD 

Permit No. 788

NRC

Summary of E

EIS SEIS

License 

No. 

SUA-1598

Proposed 

Action, 

Protection 

Measures & 

Monitoring

Impacts

Proposed Action, 

Protection Measures 

& Monitoring

Impacts

Socioeconomics Baseline § 3.14 -- 

-- 

§ 3.11 -- 

-- 

Evaluated existiconditions, incluavailability, & taforce & revenue 

Construction

§§ 4.15.1 & 

4.15.2 

§§ 4.15.3, 

4.15.4.1, 

4.15.5, 

4.15.6.1, 

4.15.8 & 

4.15.9 

§ 2.1.1.1.2.6 

§§ 4.11.1.1, 

4.11.2, & 

4.11.3

Continue workinthrough commitsocioeconomic c

Operation

§§ 4.15.3, 

4.15.4.2, 

4.15.5, 

4.15.6.2, 

4.15.8 & 

4.15.9 

-- 

§§ 4.11.1.2, 

4.11.2, & 

4.11.3

Reclamation

§§ 4.15.3, 

4.15.4.3, 

4.15.5, 

4.15.6.3, 

4.15.8, & 

4.15.9 

-- 

§§ 4.11.1.3, 

4.11.1.4, 

4.11.2, & 

4.11.3

The need for pro

Environmental Justice Baseline -- -- 

-- 

§ 3.11 -- 

-- 

Evaluated existi

Construction

§§ 4.16.1, 

4.16.4 § 4.16.3 -- 

§§ 4.12.1.1, 

4.12.2, 4.12.3 

The need for pro

Operation §§ 4.12.1.2, 4.12.2, 4.12.3 Reclamation

§§ 4.12.1.3, 

4.12.1.4, 

4.12.2, 4.12.3 
REC

ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

October 2012

Table 2 Cross-References to Discussions of Environmental Protection Measures, Monitoring, and 

LQD and NRC Documents (Page 7 of 7) 

Agency

BLM

WDEQ-LQD 

Permit No. 788

NRC

Summary of E

EIS SEIS

License 

No. 

SUA-1598

Proposed 

Action, 

Protection 

Measures & 

Monitoring

Impacts

Proposed Action, 

Protection Measures 

& Monitoring

Impacts

Public & Occupational Health Baseline -- -- Appendix D10 § 3.12.2 -- 

Conditions 

10.4, 12.2, 12.3, 12.5, 

12.9 through 

12.11, & 

12.14 

Analyzed soil, vtissue, & particuparameters. Addbefore start-up. 

Construction

§§ 2.1.2.6, 

2.3.3.8, 2.1.7, 4.17.1, 4.17.5 

§§ 4.17.4.1, 

4.17.4.2, & 

4.17.5

§§ OP 2.9, OP 5.0, 

OP 5.1.1, & OP 

5.2.2.1 

-- 

§§ 4.13.1.1, 

4.13.2, & 

4.13.3

Conditions 

9.7, 

10.14 -10.17, 

11.2, 11.6, & 

12.12 

Employee traini

maintenance. Pl

contamination fr

Operation

§§ 2.1.4.4, 

2.3.3.1, 2.3.3.5, 

2.1.7, 4.17.1, 

4.17.5 

-- 

§§ 4.13.1.2, 

4.13.2, & 

4.13.3

Conditions 

9.7, 

10.14 -10.17, 

11.6 & 12.12 

Reclamation §§ 2.1.7, 4.17.1, 4.17.5 §§ RP 2.2, RP 4.0, & RP 4.1 through 4.3 §§ 2.1.1.1.4 through 2.1.1.1.6 §§ 4.13.1.3, 4.13.1.4, 4.13.2, & 4.13.3 Conditions 9.7, 10.14 -10.17, 11.6, 12.12 & 12.13 Decontaminatio

accordance with 

Waste Management Baseline -- -- -- §§ 3.13 -- 

Conditions 

9.6, 9.9, 

11.1(D) & 

12.6 

Evaluated existioptions. Estimagenerated. Desinecessary (e.g., 

Construction

§§ 4.18.1 & 

4.18.2 

§§ 4.18.3, 

4.18.4, & 

4.18.5

§ OP 5.0 

§§ 2.1.1.1.2.5 & 

2.1.1.1.6 

§§ 4.14.1.1 & 

4.14.1.1.1 

Construct approI wells). Reduce recycling materistorage, handlin

Operation §§ 2.1.1.1.3.2 & 2.1.1.1.6 §§ 4.14.1.1 & 4.14.1.1.2 Reclamation §§ RP 4.1 through 4.3 §§ 2.1.1.1.5 & 2.1.1.1.6 §§ 4.14.1.1, 4.14.1.1.3, & 4.14.1.1.4 Decontaminate f

during reclamatiwith permits & r

Financial Surety (Reclamation Bond) Amount determined by WDEQ-LOQ, NRC, and the BLM; approved surety instruments held by WDEQ-LQD and available to NRC and the BLM. Amount re

instruments increased if review indicates increase required. 
RECORD OF DECISION

22 ROD – LOST CREEK URANIUM IN-SITU 

Table 3 Project Monitoring (Page 1 of 5) 

Monitoring Activity Description Project Phases Construction Operation Rec

Air Quality Meteorological Station Hourly measurements. X X Removed upoDust Control

Daily observations. Additional requirements may be part of WDEQ-AQD permit. 

X X Until on-sit

activitie

Radiation: Radon Gas and Direct Gamma

Continuous monitoring, quarterly analysis reported to NRC semiannually. X

Until mine un

plant deco

co

Archaeology and Cultural Resources Mitigation and Confirmation of Survey 

Prior to construction and mine unit development.SHPO evaluation. 

X 

Equipment Performance – Basic and Radiation Safety Mine Units, Plant, and Waste Areas Daily walk through. X

Until daily o

completed

personn

Equipment Performance – Effluent Control Storage Ponds

Daily, weekly, quarterly, and annual inspections/assessments; report leaks to NRC.Additional requirements may be part of EPA NESHAPs permit. 

 X Until recla

di

UIC Class I Well(s)

Annual evaluation, report to NRC and WDEQ. Additional reporting requirements may be part of UIC Permit. 

 X Until wel

Equipment Performance – Fluid Transfer and Processing Pipelines and Process Tanks 

Automated with pressure gauges and alarms. X Until mine un

processing op
REC

ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

October 2012

Table 3 Project Monitoring (Page 2 of 5) 

Monitoring Activity Description Project Phases Construction Operation Rec

Equipment Performance – Mine Unit Balance Injection and Production Flow Rates and Pressures 

Daily measurements and balancing. X Until ground 

co

Mining Progress Evaluated annually, report to NRC and WDEQ. X Equipment Performance – Wells and Pipelines Pipeline Integrity Prior to use. X Mechanical Integrity Testing of Wells

Prior to use. X Once every five years and after well repair, WDEQ-LQD may require a different monitoring frequency. 

 X 

Downhole Injection Pressures 

Automated with pressure gauges and alarms. X 

Groundwater Aquifer Testing and Monitor Well Sampling Before start-up of each mine unit. X On-Site Baseline Wells Quarterly reports to NRC and WDEQ-LQD. X XExcursion Detection Monitoring

Twice per month with additional measurements if excursion is detected. 

 X

Off-Site BLM wells Quarterly evaluation, report to NRC, BLM, and WDEQ-LQD. X Until stability 

mine 

Restoration Progress 

Daily, weekly, and monthly analyses as needed, report to NRC, BLM, and WDEQ-LQD. 

 
RECORD OF DECISION

24 ROD – LOST CREEK URANIUM IN-SITU 

Table 3 Project Monitoring (Page 3 of 5) 

Monitoring Activity Description Project Phases Construction Operation Rec

Stability Monitoring 

Quarterly for twelve months, two additional samples taken in the six months following the initial sampling, report to NRC, BLM, and WDEQ-LQD. 

 

Health (radiation-related) Radon Monthly with increases to weekly under specific conditions. X Bioassay

Initial and exit sample for all on-site workers and monthly for workers in specified areas. 

 X 

Security Monitoring of fenced areas, visitors, and shipments. X Soils Evaluation of Topsoil Removal Practices X Evaluation of Topsoil Protection Measures Minimum quarterly evaluations. X XRadiation Before and after removal of facilities, report to NRC and BLM. Topsoil Viability Before reclamation. Replacement Depths Whenever soil is replaced, report to WDEQ-LQD and BLM. Surface Water Storm Water Runoff Controls Quarterly evaluation. X X Water Quality Sampling and reporting per WYPDES. X X Until ground

mine unit rec

decommissio
REC

ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

October 2012

Table 3 Project Monitoring (Page 4 of 5) 

Monitoring Activity Description Project Phases Construction Operation R

Surface Water Monitoring only in case of spill or other accidents. X Transportation Transportation Risk

Sweetwater County Public Works Director, Road Use and Maintenance Agreement. Meet requirements identified in the agreement. Records of shipments, driver training, vehicle safety inspections, and maintenance work will be kept. 

X X 

Road Conditions Minimum quarterly inspections. X Fuel Storage Minimum weekly inspections. X Vegetation Weed Control

Minimum annual evaluation, conduct following BLM guidance for weed control. 

X X 

Revegetation Success 

Annual evaluation until five seasons after successful reclamation of each disturbed area, report to BLM; Sample during the first growing season five years after reseeding, report to WDEQ-LQD. 

 

Wildlife Raptor Nests

Survey known nests and document new nests annually. X X 

Sage Grouse Leks

Survey known leks annually, including incidental survey of new leks.Aerial survey for new leks every three years. 

X X 

All Species Annual summary of accidents reported. X X 
RECORD OF DECISION

26 ROD – LOST CREEK URANIUM IN-SITU 

Table 3 Project Monitoring (Page 5 of 5) 

Monitoring Activity Description Project Phases Construction Operation Rec

All Species1 Annual Wildlife Monitoring Report submitted to BLM, WGFD. X X All Species Evidence of possible wildlife exposure to toxic chemicals. X X Sensitive Species Mortality of sensitive species. X X All Species Large die-offs. X X Incidents All incidents Reported to BLM. X X 

1. All species to be covered in the required report can be found in Section 4.9 of the EIS. 
RECORD OF DECISION

ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 27 

October 2012

Table 4 Additional Measures (Page 1 of 2) 

Resource Aspect Description of Measures 

Land Use Cadastral 

Monument

Government survey markers and monuments are 

protected per 18 USC 1858 and 43 CFR 3809.420. 

Any changes, damages, or removal of survey 

monuments or markers will be immediately 

reported to the Authorizing Official. 

Transportation Roads LCI will obtain a Road Use and Maintenance 

Agreement from the BLM for any crossing, access 

to, or use of a BLM-controlled road outside the 

permit boundary. 

Surface Water Ephemeral 

Drainages 

Surface disturbing activities will be avoided 

within 20 feet of the inner gorge of ephemeral 

channels identified on Figure 3.5-1 in the FEIS or 

identified in the field by best professional 

judgment as a channel that meets the BLM 

guideline criteria of a “defined channel formed in 

response to ephemeral surface conditions.” 

Exceptions to this will be granted by the BLM 

based on an environmental analysis and sitespecific engineering and mitigation plans as 

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

actions within areas that could not be avoided and 

that will provide protection for the resource 

identified will be approved. 

Groundwater Stability 

Monitoring

As part of the reclamation plan and associated 

monitoring, required per the 43 CFR 3809 

regulations, at least two additional stability 

monitoring samples will be collected, once every 

three months over a six-month period, after the 

initial stability period. The monitoring 

information will also support combined agency 

review of current stability monitoring 

requirements. 
RECORD OF DECISION

28 ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

October 2012

Table 4 Additional Measures (Page 2 of 2) 

Resource Aspect Description of Measures 

Wildlife –

Greater 

Sage-Grouse 

Adaptive 

Management 

To ensure continued coordination and consultation with 

other local, state, and federal agencies and consistency 

with other agency plans, policies, and agreements, a 

Technical Advisory Committee (the BLM, WGFD, and 

LCI) will be established to develop the Adaptive 

Management Plan to complement on-going baseline 

data collection and existing stipulations. 

Wildlife Fencing Fencing around the Storage Ponds will be upgraded to 

Type II fencing (WDEQ Guideline No. 10 [1994]) to 

preclude deer, antelope and elk. 

Wildlife Fencing New fence construction will be authorized according to 

the BLM standards unless modified following 

consultation with affected parties. All fencing will be 

wildlife-friendly fencing, with appropriate collision 

deterrents, with the exception of the fencing around the 

Storage Ponds, which will be exclusion fencing. 

Wildlife Storage Ponds The operator will monitor selenium levels in the storage 

ponds on a weekly basis. If selenium levels were to 

reach 0.02 mg/L, or above, in the storage ponds, 

mitigation measures will be required to prevent 

mortality of any protected birds in accordance with 

federal and state regulations, as required per 43 CFR 

3809.401(b)(4). Potential mitigation measures include 

those to keep selenium levels below 0.02 mg/L, 

covering the storage ponds, or other mitigation 

measure(s) to be approved by the BLM wildlife 

biologist. 

Wildlife Storage Ponds The BLM will require the applicant to obtain a 

Pesticide Use Proposal with associated environmental 

analysis and consider other Integrated Pest 

Management techniques, prior to authorizing the use of 

pesticides. 

Wild Horses Access to 

Fenced Pattern 

Areas

To help protect healthy herds of wild horses, LCI will 

likely implement cattle guards to deter wild horse 

access to a pattern area if gate of the fencing 

surrounding the pattern area were inadvertently left 

open. The cattle guards would be equipped with wings, 

and rods would be welded between the pipes to prevent 

horse injuries. 

Visual and 

Scenic 

Resources 

Building 

Completion

To help maintain the overall objectives of visual 

resource class, paint colors will conform to the BLM 

Standard Environmental Color Chart CC-001. 

 
RECORD OF DECISION

ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 29 

October 2012

6.0 Public Involvement and Agency 

Consultation and Coordination

Public involvement and agency consultation were conducted in accordance with 

NEPA guidelines (40 CFR 1506.6 and 1501.6). As the Project completed the 

permitting processes for the NRC, WDEQ, and Sweetwater County, public 

meetings for the Project were held, prior to the BLM’s NEPA review. For NRC 

to meet its NEPA requirements for evaluation of handling and managing uranium, 

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). The WDEQ permitting processes also required public notice and 

comment (AQD, Wyoming Air Quality Standards and Regulations, Ch. 6, Sec. 

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

Quality Rules and Regulations, Ch. 13, Sec. 19), and these requirements were 

met, including notice and opportunity to participate in the Wyoming 

Environmental Quality Council (EQC) Hearing on the WDEQ-LQD Permit to 

Mine in August 2011 (resulting in the EQC upholding the WDEQ-LQD 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). 

The public scoping period for the BLM’s NEPA review 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, D.C. office and the BLM’s quarterly congressional briefing. 

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

syndicated string of radio stations in southwest Wyoming. Several agencies, state 

and local government representatives, Native American tribes, local media, and 

interested organizations and individuals also received a public scoping 

notification via e-mail or mail. 

Organizations and agencies were mailed letters of invitation to become 

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

organizations included: the 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 BLM worked closely with the EPA during 

the NEPA process. The following agencies participated as cooperating agencies: 

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

Sweetwater County Commissioners. 

A public scoping meeting was held at the BLM Rawlins Field Office on March 7, 

2011. During the public scoping period, ten comment submittals (e.g., letter, 

comment form) were received and contained 57 comments. These comments 

were evaluated to identify key issues and concerns and to develop alternatives. 
RECORD OF DECISION

30 ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

October 2012

Tribes, individuals, organizations, and agencies have been and continue to be 

consulted regarding the Project. In compliance with Section 7 of the Endangered 

Species Act of 1973, as amended, NRC and the BLM consulted with the USFWS 

to ensure any actions authorized, permitted, or otherwise carried out will not 

jeopardize the continued existence of any listed species or adversely modify 

designated critical habitats. NRC initiated Section 106 consultation with the 

Wyoming SHPO in 2008 and in 2010, a Memorandum of Agreement was 

finalized among the NRC, Wyoming SHPO, the BLM, the Northern Arizona 

Tribe, the Eastern Shoshone Tribe, and LCI. 

The BLM published a Notice of Availability (NOA) on April 27, 2012, for the 

DEIS for the proposed Project (77 FR 25193). A public DEIS informational 

meeting was held in Rawlins on May 14, 2012. The public comment period was 

45 days with comments due on June 11, 2012. The BLM received 22 comment 

submittals. The comments and the BLM’s responses were included as Appendix 

F in the FEIS. 

The NOA for the FEIS was published in the Federal Register on August 17, 2012, 

followed by a 30-day review period. During this time, the BLM received seven 

letters commenting on the Project. The letters were read thoroughly for 

substantive comments, and responses were drafted. A summary of the comment 

and response process, the substantive comments, the BLM’s responses, and the 

original letters received are included in Appendix B of this ROD. 

7.0 Appeal of Decision

If you do not agree and are adversely affected by this decision, you may request 

that the Wyoming BLM State Director review this decision. If you request a State 

Director review, the request must be received in the Wyoming BLM State Office, 

P.O. Box 1828, Cheyenne, WY 82003-1828, no later than 30 calendar days after 

you receive this decision. The request for State Director review must be filed in 

accordance with the provisions in 43 CFR 3809.805. This decision will remain in 

effect while the State Director review is pending, unless the State Director grants 

a stay. If you request a stay (suspension), you have the burden of proof to 

demonstrate that a stay should be granted. 

If the State Director does not make a decision on your request for review of this 

decision within 21 days of receipt of the request, you should consider the request 

declined. Under 3809.809(a) denial of a request for State Director review cannot 

be appealed. 

You may appeal this Record of Decision to the Interior Board of Land Appeals 

(IBLA) by following the procedures at 43 CFR 4.413. You may contact the BLM 

Wyoming State Office to determine when BLM received your request for State 

Director review. You have 30 days from the end of the 21-day period in which to 
RECORD OF DECISION

ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 31 

October 2012

file a notice of appeal with the High Desert District Office, 280 Highway 191 

North, Rock Springs WY 82901, with a copy to the Office of the Regional 

Solicitor, U.S. Department of the Interior, 755 Parfet Street, Suite 151, Lakewood, 

Colorado 80215. The High Desert District Office will forward a copy of your 

notice of appeal to the IBLA 

If you wish to bypass a State Director review, this Record of Decision may be 

appealed directly to the IBLA in accordance with the regulations at 43 CFR 

3809.801(a)(1) and 43 CFR Part 4 Subpart E. Your notice of appeal must be filed 

within 30 days of the date of this Record of Decision at the High Desert District 

Office, with a copy to the Office of the Regional Solicitor. The High Plains 

District Office will forward the appeal to the IBLA. As the appellant, you have 

the burden of showing that the decision appealed is in error. BLM form 1842-1 

contains further information on taking appeals to the IBLA. 

7.1 Request for Stay 

If you wish to file a petition (request) pursuant to regulations 43 CFR 4.21(a)(2) –

for a stay (suspension) of the effectiveness of this decision during the time that an 

appeal is being reviewed by the board – the petition for stay must accompany 

your notice of appeal. 

Except as otherwise provided by law or other pertinent regulations, a petition for a 

stay of a decision pending appeal shall show sufficient justification base on the 

following standards: 

 

1) The relative harm to the parties if the stay is granted or denied; 

2) The likelihood of the appellant’s success on the merits; 

3) The likelihood of immediate and irreparable harm if the stay is not 

granted; and 

4) Whether the public interest favors granting a stay. 

The appellant requesting a stay bears the burden of proof to demonstrate that a 

stay should be granted. A copy of the notice of appeal and petition for stay must 

also be submitted to each party named in this decision and to the Interior Board of 

Land Appeals and to the appropriate Office of the Solicitor (see 43 CFR 4.413) at 

the same time the original documents are filed with the Authorized Officer at the 

High Desert District. 

 

RECORD OF DECISION

ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 33 

October 2012

8.0 References

Bureau of Land Management (U.S.). 1987. Lander Resource Management Plan, 

Final EIS. Lander Field Office (WY). Available from: 

http://www.blm.gov/rmp/WY 

Bureau of Land Management (U.S.). 2008. Record of Decision and Approved 

Rawlins Resource Management Plan, EIS. Rawlins Field Office, Rawlins, 

Wyoming. Available from: 

 http://www.blm.gov/wy/st/en/programs/Planning/rmps/rawlins/rod_armp.

html. Accessed on 17 July 2011. 

Council on Environmental Quality. 2011. Environmental Justice: Guidance Under 

the National Environmental Policy Act. Washington (D.C.): Executive 

Office of the President. Available from: 

http://ceq.hss.doe.gov/current_developments/docs/Mitigation_and_Monito

ring_Guidance_14Jan2011.pdf. Accessed on 24 July 2012. 

U.S. Congress. 2005. Energy Policy Act of 2005. H.R.6. Available from: 

http://thomas.loc.gov/cgi-bin/bdquery/z?d109:H.R.6:. Accessed on 30 July 

2010.

Lost Creek ISR, LLC. 2009. Announcement of Sweetwater County Approval of Lost 

Creek Development Plan. Available from: 

http://www.ur-energy.com/storage/investor-info/newsreleases/2009/20091203_Approval_of_LC_Development_Plan_by_Sweetwat

er_County.pdf

Lost Creek ISR, LLC. 2011a. LCI’s Closing Argument Before the Environmental 

Quality Council, State of Wyoming, in the Matter of the Objection to the 

Mine Permit of Lost Creek ISR LLC TFN 4 6/268. Docket No. 11-4803. 

Available from: 

http://deq.state.wy.us/eqc/orders/Land%20Closed%20Cases/11-

4803%20Lost%20Creek%20ISR,%20LLC/Lost%20Creek%20Closing%2

0Argument.pdf 

Lost Creek ISR, LLC. 2011b. WDEQ-LQD Permit to Mine for the Lost Creek 

Project, including Mine Unit 1, approved by WDEQ-LQD as Permit to 

Mine 788. 

Nuclear Regulatory Commission (U.S.) and Wyoming Department of Environmental 

Quality. 2009. Generic Environmental Impact Statement for In-Situ Leach 

Uranium Milling Facilities, Final Report. Washington (D.C.). NUREG-1910. 

May 2009. Available from: 

http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1910/ 

Accessed on 7 April 2010. 
RECORD OF DECISION

34 ROD – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT 

October 2012

Nuclear Regulatory Commission (U.S.). 2011a. Environmental Impact Statement 

for the Lost Creek ISR Project in Sweetwater County, Wyoming: 

Supplement to the Generic Environmental Impact Statement for In-Situ 

Leach Uranium Milling Facilities. Washington (D.C.). NUREG-1910, 

Supplement 3. Available from: 

http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1910/s3/ 

Nuclear Regulatory Commission (U.S.). 2011b. Materials License Number 

SUA-1598. Washington (D.C.). Available from: 

http://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber

='ML111940049' 

Wyoming Department of Environmental Quality (WDEQ). 1994. Land Quality 

Division. Guideline No. 10, Fencing. Cheyenne (WY). Available from: 

http://deq.state.wy.us/lqd/guidelns/Guide10=8-94.pdf. 

Accessed on 11 May 2011. 

Wyoming Environmental Quality Council (EQC). 2011. Findings of Fact, 

Conclusions of Law and Order in the Matter of the Objection to the Mine 

July 2012 Permit of Lost Creek ISR, LLC, Temporary Filing Number 

(TFN) 4 6/268, Docket No. 11-4803, October 5, 2011. Available from: 

http://deq.state.wy.us/eqc/orders/Land%20Closed%20Cases/11-

4803%20Lost%20Creek%20ISR,%20LLC/Findings%20of%20Facts,%20

Conclusions%20of%20Law%20and%20Order0001.pdf