2.0 PROPOSED ACTION AND ALTERNATIVES

FINAL EIS – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT – VOLUME I 2-1 

July 2012

2.0 PROPOSED ACTION AND 

ALTERNATIVES

LCI proposes to develop ISR of uranium within the Permit Area. Approving the 

Proposed Action would result in development of the federal mineral estate and the 

disturbance and reclamation of public lands administered by the BLM. Under 43 

CFR 3809, mining operations that perform more than ‘casual use’ activities on 

five or more acres of public lands must submit a Plan of Operations to the BLM 

for review and approval. A synopsis of the Plan of Operations, NRC License, and 

the WDEQ-LQD Permit to Mine, including a summary of site facilities, schedule, 

and operation and reclamation plans, is presented in Section 2.1.

Under the rules and regulations of NRC and WDEQ-LQD, mines are required to 

collect extensive baseline information and to implement extensive monitoring 

programs and protective measures. These agency-required measures are 

considered part of the Proposed Action, as submitted in the Plan of Operations, 

and the alternatives considered in this document. These measures, and the 

additional measures required by the BLM, are mentioned in Section 2.1 and 

addressed in more detail in Section 2.2.

Section 2.3 provides information on alternatives to the Proposed Action, 

including the No Action Alternative as required under NEPA. Under that 

alternative, development of the Project on BLM-administered land would not be 

allowed. Section 2.3.1 describes the alternatives considered in detail, and Section 

2.3.2 provides a comparative summary of the impacts from those alternatives. 

The alternatives considered but eliminated from detailed analysis, and the

rationale for eliminating them in accordance with 40 CFR 1502.14, are discussed 

in Section 2.3.3.

2.1 Proposed Action 

2.1.1 Summary of the Proposed Action 

As discussed in Section 1.0, the Permit Area contains approximately 4,254 acres, 

and the surface to be affected by the Project would total approximately 345 acres 

(see Section 4.5 for specific disturbance areas). The majority of the surface 

disturbance would follow the ore trend through the Permit Area (Figure 2.1-1).

The mine units (following the ore trend), the Lost Creek Plant (Plant), the Storage 

Ponds, the disposal wells, and the roads are the significant surface features 

associated with the ISR operation. An illustration of a typical ISR operation, such 

as the Project, is shown on Figure 2.1-2. 
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A uranium ISR operation extracts the mineral from permeable, uranium-bearing 

sandstones through a series of mine units. The mine units follow the ore body 

identified by exploration and delineation drilling. Exploration drilling evaluates 

host stratigraphic formations and better defines the location and nature of the 

uranium deposit. A series of exploration holes are drilled on wide-spaced 

‘fences’ to characterize the local geology. These holes are generally hundreds to 

thousands of feet apart. After the discovery of a mineralized zone, closely-spaced 

exploration drilling (e.g., drilling with spacing of fifty to a few hundred feet) is 

conducted to characterize the extent, grade, and amenability of the mineralized 

zone. If the resource is sufficient and the economics are desirable, the zone would 

be classified as an ore body. Delineation drilling is generally on closer spacing 

than exploration drilling and is used to better define the ore resources for design 

of the mine units. (The ore deposits within the Permit Area 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 scale and number of the mine units for a given ISR operation depend on a 

variety of factors, including ore distribution, aquifer characteristics, plant capacity 

design, and operational feasibility. In Wyoming, a Hydrologic Test Proposal for 

each individual mine unit is submitted to WDEQ-LQD for review and approval 

prior to installation and operation of a new mine unit. Following completion of 

the activities described in the proposal, a Hydrologic Test Report is submitted to 

WDEQ-LQD for review and approval. The Hydrologic Test Proposal and Report 

detail: subsurface conditions (structural geology and results of the hydrogeologic 

pump tests); monitor well locations and depths; pattern areas and depths; surface 

conditions (including mine unit layout, soil, and vegetation); baseline water 

quality sampling results; the impact of faulting; potential interference; mine unit 

operations (including upper control limit calculations, historic drill hole locations, 

and well permit information); and restoration and reclamation. 

Each mine unit consists of patterns of production and injection wells (i.e., the 

pattern area) within a ring of monitor wells. The injection and production well 

pattern design would be based on conventional five-spot patterns, modified as 

necessary to fit the characteristics of the ore body. (In the Proposed Action, the 

injection wells are expected to be spaced 75 to 150 feet apart. The injection and 

production wells would be installed in the mineralized HJ Horizon, which is about 

350 to 500 feet below the ground surface.) Water quality samples would be 

collected from the ring of monitor wells and analyzed to detect a horizontal 

excursion (unanticipated movement of lixiviant) 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 

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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 provide 

information on the mining process and may double as production or injection 

wells. 

A lixiviant is pumped from the Plant through buried pipelines to the injection 

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

thereby allowing the dissolution of uranium in groundwater. (The Proposed 

Action applies a carbonate lixiviant.) After circulation through the production 

zone (i.e., from the injection wells to the production wells), the resulting uraniumladen solution (i.e., pregnant lixiviant) 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). The 

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

additional uranium. As in the case of the Proposed Action, storage ponds may be 

used in conjunction with UIC Class I wells for waste water disposal at depths 

between 6,139 and 9,590 feet below the ground surface. 

The Proposed Action would be conducted in phases including Construction, 

Operation, and Reclamation. During the Initial Construction stage, the Plant and 

associated utilities would be built, the Storage Ponds and UIC Class I Wells 

would be installed, and the East and West Access Roads would be upgraded. The 

Mine Unit Development stage would also be included in the Construction phase, 

although the development of the mine units would be progressive (so that one 

mine unit may be in operation while another is being developed). Similarly, 

Reclamation would include both the progressive reclamation of mine units and 

the final reclamation of the Plant. Therefore, some of the Construction, 

Operation, and Reclamation activities would overlap. The major work under each 

phase is outlined in Section 2.1.4.

2.1.2 Site Facilities 

2.1.2.1 Process Plant and Utilities 

The Plant would be one of the first features to be constructed in the Permit Area. 

The Plant would house four distinct process circuits: the ion exchange circuit 

(also called the resin-loading circuit), the elution circuit, the 

precipitation/filtration circuit; and the dryer circuit. The layout of the Plant is 

presented in Figure 2.1-3. The Plant would be capable of processing 6,000 

gallons per minute (around 1.0 million pounds U3O8 per year) and normally

operate at 90 percent of its designed capacity. Additional details on the Plant 

processes are available in the documents of the WDEQ-LQD Permit to Mine and 

the NRC License (LCI, 2010 and 2011b). 

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2.0 PROPOSED ACTION AND ALTERNATIVES

Electrical power would be brought into the Permit Area, through the installation 

of a new overhead line (Figure 1.2-2), from the existing transmission line located 

along the western edge of the Permit Area. The overhead line would branch to 

transformer poles located throughout the mine units, the UIC Class I wells, and at 

the Plant. The overhead power lines would continue from the transformer poles 

to the service points within the mine units (the header houses), where power to the 

production and injection wells would be transmitted through underground lines 

(tertiary lines) located along the same corridors as the buried pipelines for fluid 

transmission to and from the wells. All power lines to the point of transform 

(from 34,500 volts to 480 volts) would be overhead lines that comply with 

regional raptor specifications. Additional details on the electrical utility are 

available in the documents of the WDEQ-LQD Permit to Mine and the NRC 

License (LCI, 2010 and 2011b). 

There are two sets of pipelines, one conveys fluids to and from the mine units and 

the other conveys fluids to the UIC Class I wells. The pipelines to and from the 

mine units would consist of a main trunk line to the Plant that would be extended 

to the individual mine units as they are developed. The pipelines to each UIC 

well would be installed as each well is brought on-line. The pipeline corridors 

would follow roads wherever possible to minimize disturbance. 

2.1.2.2 Storage Ponds 

Two fenced 160-by-260-foot Storage Ponds would be constructed adjacent to the 

Plant as shown on Figure 2.1-3. The primary purpose of the Storage Ponds 

would be to allow for shut down of the UIC Class I wells for maintenance, such 

as Mechanical Integrity Tests (MITs), or repair while the Plant remains in 

operation. The total capacity of the Storage Ponds is designed to accommodate 

two weeks of reduced Plant operation and is redundant, allowing for maintenance 

of the Storage Ponds in the event of a liner problem. The Storage Ponds would be 

lined with a double synthetic liner, including a leak detection system, and a series 

of monitoring wells would be installed to detect leaks into the surrounding 

sediments. In May 2010, the WSEO granted Permit No. 13595R to LCI for the 

construction of the two Storage Ponds. In November 2010, LCI submitted an 

application for approval of the pond construction to EPA to evaluate compliance 

with the National Emissions Standards for Hazardous Air Pollutants (NESHAP) 

for radon, and that application was approved in December 2011. A complete 

description of the Storage Ponds and associated monitoring is provided in 

Sections OP 2.9.4 and OP 5.2.2.1 of the Operations Plan in the WDEQ-LQD 

Permit to Mine (LCI, 2011b) and Sections 4.2.5.4 and 5.3.2 of the NRC Technical 

Report (LCI, 2010). 

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FINAL EIS – LOST CREEK URANIUM IN-SITU RECOVERY PROJECT – VOLUME I 2-7