4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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4.0	 ENVIRONMENTAL PROTECTION 

MEASURES, MONITORING, AND IMPACTS 

This section describes the direct and indirect environmental impact of the 

Proposed Action and alternatives. Direct and indirect impacts are disclosed in 

Section 4.0 and the cumulative impact analysis is discussed later in Section 5.0. 

Each resource section begins with a summary of the agency-required measures 

and LCI’s project design commitments necessary to comply with all federal and 

State environmental statutory and regulatory requirements. A description of the 

monitoring protocols for each resource follows the agency and LCI required 

measures summary. References to the sources of the required protection 

measures, such as the NRC SEIS and license or the WDEQ-LQD Permit to Mine 

(Section 1.4), are cited as well. The impact significance criteria and the impacts 

are then presented. The impacts from the Proposed Action are evaluated first. 

The impacts from the No Action Alternative and the Other Alternatives are then 

evaluated. 

Mitigation measures, residual impacts, irreversible and irretrievable commitments 

of resources, and the relationship between short-term uses and long-term 

productivity are separate subsections at the end of Section 4.0. 

4.1 Resource Impact Evaluations 

The evaluation of impacts from the Proposed Action is, for the most part, 

organized by resource, e.g., vegetation, and by phase of the Proposed Action, e.g., 

construction. For more effective evaluation of impacts for some resources, e.g., 

environmental justice, the evaluation of impacts may be organized somewhat 

differently. 

The resources are presented in the same order as in Section 3.0. As discussed in 

detail in Section 2.1.1, three phases of the Project are defined: Construction; 

Operation; and Reclamation. Construction applies to the initial major facility 

construction, e.g., the Plant, access roads, and the five UIC Class I deep wells. For 

the purposes of this evaluation, it has been assumed that all of the equipment 

staging areas and deep wells would be installed at the beginning of the Project, 

although this would probably not be the case. The first deep well was installed in 

2008 to provide the necessary subsurface information on the feasibility of the 

wells, and fewer than five deep wells will probably be needed. Construction also 

includes Mine Unit Development, e.g., the drilling, testing, and installation of 

each mine unit, which would occur throughout the life of the Project. The 

facilities being constructed during the Mine Unit Development, e.g., header 

houses, are smaller than those in the initial Construction. Because of the 

similarities of impacts from exploration and delineation drilling, exploration 

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drilling is included under Mine Unit Development, although it may occur outside 

a designated mine unit. Operation includes the production of ore from the mine 

units, and Reclamation includes the reclamation of each mine unit, as well as the 

Final Reclamation of the major facilities, such as the Plant. As noted in Section 

2.1, the operation and reclamation of the mine units would progress sequentially. 

The Other Alternatives for the Project are described in detail in Section 2.3, of 

which two were chosen for additional evaluation: Not Fencing the Pattern Areas 

and Drying Yellowcake On-Site. Environmental and social impacts were 

evaluated and presented in this section for these alternatives. In large part, the 

impacts of the Other Alternatives differ little from those of the Proposed Action. 

For the impact evaluations, it has been assumed that in addition to the permits and 

licenses already acquired, LCI would acquire any additional necessary federal, 

state and local permits/licenses and approvals for the Project, and the 

requirements of those permits would be met. It has also been assumed that LCI’s 

committed environmental and social management measures, including those 

described in Section 2.1 and the agency-required and LCI committed measures 

and monitoring measures described in this section are fully and properly 

implemented. For comparison and easier reference, the findings from the NRC 

SEIS are included for each resource. 

4.1.1 Impact Significance 

For each resource, the criteria used to gauge the significance of the impact are 

discussed. In many cases, the criteria are based on quantitative regulatory 

requirements and scientific documentation. In other cases, the criteria may be 

more qualitative. The vulnerability of a given resource and perceptions about 

resource impacts are also considered. 

4.1.2 Impact Scale 

For each resource, a different scale is necessary for substantive evaluation of 

direct and indirect impacts. For example, vegetation impacts can be evaluated 

within the vicinity of the site because of the similarity of the vegetation types in 

the area. However, the socioeconomic impacts must be evaluated over a much 

larger area, e.g., 100 miles, because of the limited number of population centers in 

this part of Wyoming. In some cases, e.g., for noise, the impacts on-site and offsite have been differentiated. Another consideration in the impact scale is the 

geographic setting, e.g., inside or outside the Basin. 

4.1.3 Impact Duration 

For all resources, unless specific exceptions are stated, ‘short-term’ impacts are 

those that would occur over a five-year period or less, in some cases, only over a 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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period of weeks. The ‘long-term’ impacts are those that would exceed five years. 

Impacts that could affect future usage of the site are considered as residual 

impacts. 

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4.2 Land Use 

4.2.1 Agency-Required Measures 

The existing land uses, all of which may be affected by the Project, are: livestock 

grazing, wildlife habit, dispersed recreation, mineral and energy development, and 

infrastructure. The planned post-operational use of the Permit Area is livestock 

grazing and wildlife habitat. Since the disturbed land would be reclaimed after 

the Operation phase, the Project is compatible with the planned future use. The 

Project would conform to the land use regulations of Carbon and Sweetwater 

Counties in Wyoming. 

The required environmental protection measures are summarized below from 

Sections OP 2.5, OP 2.9, OP 3.5, RP 3.3, and RP 4.5 of the WDEQ-LQD Permit 

to Mine (LCI, 2011b), Section 7.5.2 of the NRC Technical Report (LCI, 2010), 

Sections 2.1.1.1.2.1, 2.1.1.1.4.4, 2.1.1.1.4.5, and 2.1.1.1.5, and 6.2.2 of the NRC 

SEIS (NRC, 2011a), and Conditions 11.6 and 12.13 of the NRC License (NRC, 

2011b). 

Based on the BLM review of the agency-required measures, an additional 

measure was added relating to new fence construction and addresses potential 

discrepancies between BLM and WDEQ-LQD fencing criteria. Fences would be 

constructed according to BLM standards unless modified following consultation 

with affected parties. All fencing would be ‘wildlife’ friendly fencing, with 

appropriate collision deterrents, with the exception of the fencing around the 

Storage Ponds, which would be exclusion fencing. 

Livestock Grazing and Wildlife Habitat 

The primary protection measures are to: limit disturbance wherever possible; 

locate new disturbance on old, unreclaimed disturbance wherever possible (e.g., 

new roads following old two-tracks); locate disturbance in upland areas, rather 

than the less common lowland areas; and reclaim the disturbance as soon as 

possible in a manner that would support the post-mining land uses. More 

protection measures related to specific resources or activities are discussed in the 

sections on those resources or activities. For example, increased dust from 

Construction activities could make forage along the access roads less palatable. 

Required measures to reduce dust (and other traffic-related impacts) are discussed 

in more detail in Sections 4.3.1 (Transportation) and 4.11.1 (Air Quality) and 

would include wetting unpaved roads and establishing speed limits on unpaved 

roads. Similarly, seeding inactive Construction areas to limit erosion and reestablish vegetation cover is discussed in Section 4.8.1 (Vegetation). 

Dispersed Recreation 

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The primary protection measure is to limit access, only to the extent necessary to 

protect the health and safety of the public. More protection measures related to 

specific resources or activities related to dispersed recreation are discussed in the 

sections on those resources or activities. For example, required measures to limit 

visual impacts are discussed in Section 4.14. 

Mineral and Energy Development 

To avoid interference among mineral and energy development projects, it is 

anticipated that any development in the Permit Area, other than uranium, would 

either be delayed for the duration of the Project or intermixed within the overall 

Permit Area. However, there are no known minerals (other than uranium), or oil, 

gas or coal resources in the Permit Area proposed for mining or development. To 

minimize potential interference with future subsurface activities, all the Project 

drill holes and wells would be abandoned in accordance with applicable 

requirements. The abandonment requirements for the drill holes and mine unit 

and water supply wells are listed in Sections OP 2.12 and RP 3.1 of the WDEQLQD Permit to Mine (LCI, 2011b), and the requirements for the UIC Class I wells 

are in Attachment J of the WDEQ-WQD application, which is included in 

Attachment ADJ-2 of the WDEQ-LQD Permit to Mine. In addition, notice of the 

presence of the abandoned wells is also required via a deed notice and/or 

individual well markers (WDEQ-LQD NonCoal Rules, Chapter 11, Section 8(h) 

[WDEQ, 2005b]). 

Infrastructure 

The only junctions with the regional infrastructure are where the Permit Area 

access roads tie into existing roads and where the transmission line to the Plant 

ties into the existing power line along the western boundary of the Permit Area. 

Required measures for road construction and installation of the transmission line 

are discussed under the resource heading that could be impacted (e.g., surface 

water or wildlife). 

4.2.2 Monitoring of Land Use Impacts 

No monitoring of land use impacts is currently planned. 

4.2.3 Impact Significance Criteria 

Interference with existing or planned land uses within or near the Permit Area is 

the impact significance criterion for land use. 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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4.2.4 Land Use Impacts from the Proposed Action 

The existing land uses, all of which may be affected by the Project, are: livestock 

grazing, wildlife habit, dispersed recreation, mineral` and energy development, 

and infrastructure. There may be some limits to these land uses in portions of the 

Permit Area during the Project, but they would not be precluded from occurring. 

4.2.4.1 Livestock Grazing 

Livestock grazing, the predominant land use within the Permit Area, would be 

directly affected by the Project as a result of fencing that affects livestock 

movement and reduces available grazing area. As noted in Section 3.1, affected 

grazing allotments within the Permit Area include: 0.7 percent of the Stewart 

Creek grazing allotment, 0.7 percent of the Cyclone Rim grazing allotment, and 

0.2 percent of the Green Mountain grazing allotment. For the 4,254 acre Permit 

Area, the total AUMs for the Permit Area is as much as 285 AUMs of cattle 

grazing in the Stewart Creek and Cyclone Rim allotments and as much as 125 

AUMs of grazing in the Green Mountain allotment. If year-round grazing were 

allowed, the Stewart Creek and Cyclone Rim allotments would provide yearround forage for the equivalent of 25 cattle in the Permit Area; the Green 

Mountain allotment would provide year-round forage for the equivalent of 8 cattle 

and 13 sheep in the Permit Area. However, as outlined below, only a portion of 

the grazing allotments within the Permit Area would be precluded from livestock 

grazing. 

Construction 

In order to ensure the health and safety of the cattle, fences would be constructed 

to limit access to livestock grazing in parts of the Permit Area. Restricted access 

to the Plant (including the Storage Ponds) and active mine unit pattern areas 

provide a beneficial impact to cattle and rangeland. Fencing ensures not only the 

health and safety of cattle currently using the land, but also provides for the 

proper reclamation of rangeland. 

If all of the proposed disturbance areas of the Project were fenced at once, 345 

acres (eight percent) of the 4,254-acre Permit Area would be removed from 

livestock grazing. Therefore, the AUMs of the Stewart Creek and Cyclone Rim 

allotments within the Permit Area would decrease by 25 cattle AUMs, from 285 

cattle AUMs to 260 cattle AUMs (reducing the number of livestock that may be 

supported by year-round forage from 25 to 21 cattle). The AUMs of the Green 

Mountain allotment would decrease by nine cattle AUMs and three sheep AUMs, 

from 95 cattle AUMs and 30 sheep AUMs to 86 cattle AUMs and 27 sheep 

AUMs (reducing the number of livestock that may be supported by year-round 

forage from eight cattle and 13 sheep to seven cattle and 11 sheep). However, the 

number of directly impacted AUMs is a conservative estimate because the 

affected acreage at any time should be less than 345 acres due to the development 

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and reclamation of the mine units in succession. The BLM calculated cattle 

production would produce $65.07 per AUM and sheep production would produce 

$41.16 per AUM of total economic impact, which includes both direct and 

secondary returns (BLM, 2004a). Using this figure, and depending on the 

allotment terms, livestock production on the Stewart Creek and Cyclone Rim 

grazing allotments within the Permit Area that may be impacted by the Project 

has a potential value of about $1,630 per year for cattle (25 AUMs x 

$65.07/AUM). Livestock production on the Green Mountain grazing allotment 

within the Permit Area that may be impacted by the Project has a potential value 

of about $590 per year for cattle (nine AUMs x $65.07/AUM) and about $125 per 

year for sheep (three AUMs x $41.16/AUM). This assumes all the cattle would 

be sold; however, some of the cows are generally kept for breeding; the same 

applies for sheep. 

Fencing would also create an obstacle to livestock movement. The greatest 

potential obstacle would be fencing of all the mine unit pattern areas at once, 

presuming the pattern areas in the mine units were continuous. Fencing of all the 

pattern areas at once would create an oblong obstacle with the greatest length of 

about 2.5 miles. Livestock would need to travel around the fencing. 

Some AUMs may be indirectly affected due to the surface disturbance from 

Construction activities that generate dust and noise, which could affect land use 

outside of the 345-acre disturbed area. Less than one percent of the three grazing 

allotments may be directly impacted; therefore, the temporary exclusion of 

livestock grazing is not expected to have a notable impact on livestock grazing. 

Impacts to livestock grazing during Construction would be confined to less than 

345 acres at any given time due to the sequential nature of the ISR operation and 

ongoing reclamation. 

Section 4.2.1.1 of the NRC SEIS summarizes the impacts the Construction phase 

could have on livestock grazing. These impacts include fencing that restricts 

grazing activities; incidental kills from vehicle accidents; and fugitive dust that 

could settle on plants making them undesirable for grazing purposes. The SEIS 

summarizes that because of the relatively small portion of land affected and the 

management measures that would be put in place to prevent vehicle-related 

livestock deaths, that the actual impact on livestock grazing would be minimal 

(NRC, 2011a). 

Operation 

Direct and indirect impacts from Operation activities would be similar to 

Construction impacts regarding access restrictions for livestock due to the existing 

infrastructure. The primary difference between Operation and Construction 

impacts would be the timing and magnitude of disturbance. Operation activities 

are estimated to occur for about seven years, versus the relatively short 

Construction period of less than one year. During the Operation phase, the 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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primary changes to land use would be the expansion of mine units. This 

expansion would have similar direct and indirect impacts as those of 

Construction. Sequentially moving active operations from one mine unit to the 

next would reduce the impact of the activities. 

In the NRC SEIS, Section 4.2.1.2 discusses the impact the Operation phase may 

have on livestock grazing. It is described as similar to the Construction phase, 

with potential problems with fugitive dust, vehicle-related livestock deaths, and 

restriction to livestock management activities being of potential concern, but 

likely leading to only minimal impacts (NRC, 2011a). 

Reclamation 

Direct and indirect impacts from Reclamation activities on livestock grazing are 

expected to be similar to Construction and Operation impacts due to the 

temporary increase in land-disturbing activities from dismantling, removing and 

disposing of facilities and equipment, restoring roads, and replacing soil. Fences, 

which restrict the movement of cattle and wild horses, would remain in place until 

vegetation is established. The sequential nature of the individual mine units and 

the ongoing Mine Unit Restoration and Reclamation would help minimize 

impacts. The land would be reclaimed to support livestock grazing. 

Sections 4.2.1.3 and 4.2.1.4 of the NRC SEIS describe the potential impacts on 

livestock grazing during the reclamation phase. These impacts would be similar 

to the Construction phase, but with the emphasis that after the land is disturbed, it 

would be returned back to a condition that would support livestock grazing and 

increase the grazing land back to its original size (NRC, 2011a). 

4.2.4.2 Wildlife Habitat 

General impacts to wildlife habitat are discussed in the following section. A 

complete evaluation of impacts to vegetation and habitat and to specific wildlife 

species is included in Sections 4.8 and 4.9. 

Construction 

Impacts to wildlife habitat generally result from activities affecting food sources 

(i.e., forage and prey), water availability, available habitat, and loss of 

effectiveness of migration corridors. Impacts to wildlife habitat would most 

likely occur during the Construction phase of the Project due to the increased 

surface disturbance. The Project, along with the associated infrastructure, is 

expected to disturb a total of 345 acres of vegetation, or about eight percent of the 

total Permit Area, throughout the duration of the Project. However, the area of 

impacted vegetation at any one time should be less than eight percent due to the 

sequential nature of the Mine Unit Development and Production as well as 

ongoing Restoration and Reclamation. This is a very small percentage of the 

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north central portion of the Great Divide Basin with similar ecological conditions 

(Chapman et al, 2004). 

Impacts to forage would occur during Construction as the result of stripping 

topsoil and vegetation to construct the Plant, roads, and other infrastructure. 

Since the affected area is small when compared with surrounding habitat, wildlife 

would likely avoid the Permit Area and use surrounding lands for sustenance and 

habitat. Increased dust from the Construction activities could also adversely 

affect available and desirable forage within the Permit Area and surrounding land. 

Water resources for wildlife consumption would not likely be impacted during the 

Construction phase. The increased noise level from Construction activities may 

adversely affect the occurrence of wildlife and deter them from the area. It is also 

possible that restricted, fenced areas within the Permit Area would fragment 

wildlife habitat. However with the exclusion of the fencing around the storage 

ponds, fencing would allow passage of pronghorn and other smaller wildlife, only 

restricting cattle and wild horses. However, the size of the Permit Area is minor in 

comparison to the surrounding identical habitat areas, to which wildlife would be 

able to exist uninhibitedly. It is expected that the direct effects to wildlife habitat 

during Construction for each mine unit would be small, short-term and confined 

to certain areas due to the sequential nature of the ISR operation and ongoing 

reclamation. 

Section 4.2.1.1 of the NRC SEIS summarizes that the impact of the land 

disturbance is insignificant, given that there is an expanse of undisturbed land that 

can serve the same function as the small portion of disturbed land (NRC, 2011a). 

Operation 

Direct and indirect impacts to wildlife habitat occurring during the Operation 

phase would be similar to those in the Construction phase. However, since there 

would be less surface disturbance activities during the Operation phase, fewer 

impacts on vegetation and wildlife habitat are expected. Additional impacts may 

occur, most likely to water resources for wildlife. The Storage Ponds that would 

intermittently contain water would be fenced to restrict wildlife access in order to 

ensure the health and safety of these animals. 

The NRC SEIS concludes that the land inaccessible to wildlife because of mining 

operations is a small portion of the region, and therefore, wildlife habitat would 

not be significantly impacted (NRC, 2011a). 

Reclamation 

Direct and indirect impacts from Reclamation activities on wildlife habitat are 

expected to be similar to Construction and Operation impacts due to the 

temporary increase in land-disturbing activities from dismantling, removing and 

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disposing of facilities and equipment, restoring roads, and replacing soil. Fences, 

which limit access to Project lands from cattle and wild horses, would remain in 

place until vegetation is established. The sequential nature of the individual mine 

units and the ongoing Mine Unit Restoration and Reclamation would help 

minimize impacts. The land would be reclaimed to support wildlife habitat. 

As with Construction and Operation, the NRC SEIS discussion of impacts due to 

Reclamation would be minimal, with a return to conditions that would support a 

variety of land uses, including wildlife habitat (NRC, 2011a). 

4.2.4.3 Dispersed Recreation 

Construction 

Impacts to dispersed recreation during Construction would be negligible due to 

the availability of equivalent surrounding land and the small area of impact. To 

protect the health and safety of the public, recreationists (including hunters) 

would have restricted access – albeit minimal – to areas within the Permit Area 

that were previously available for general use. The Plant, mine units and other 

related infrastructure would be fenced during the Construction, Operation and 

Reclamation phases. Though the general public would have restricted access to 

the Permit Area, recreationists would continue to have access to the general area 

surrounding the Project via existing roads (Wamsutter-Crooks Gap Road and 

Sooner Road)) for the duration of the Project. Traffic on these roads may be 

increased due to the additional use of the roads by vehicles bringing supplies and 

labor to the Permit Area during Construction. While the additional volume of 

traffic is not expected to affect recreational access, the increased volume of traffic 

is expected to reduce the quality of the recreational experience in the area. 

Section 4.2.1.1 of the NRC SEIS states that while recreational activity would be 

limited near the construction areas, this represents a small percentage of the total 

land of the area, and the overall impact on recreational activities is insignificant 

(NRC, 2011a). 

Operation 

As with the Construction phase, impacts to dispersed recreation during the 

Operation phase would be negligible due to continued access to the general area 

via existing roads. 

The NRC SEIS (Section 4.2.1.2) states that the Operation phase would have a 

similar influence on recreational activities as in the Construction phase (NRC, 

2011a). 

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Reclamation 

As with the Construction and Operation phases, impacts to dispersed recreation 

during Reclamation would be negligible due to continued access to the general 

area via existing roads and the relatively small restricted area of the Project. 

The NRC SEIS (Sections 4.2.1.3 and 4.2.1.4) states that the Reclamation phase 

would have a similar influence on recreational activities as in the Construction 

phase (NRC, 2011a). 

4.2.4.4 Mineral and Energy Development 

Construction 

In order to reduce the cumulative effects of mineral and energy development 

projects in the region, it is anticipated that future mineral rights for resources in 

the Permit Area, other than uranium, would either be delayed for the duration of 

the Project or intermixed within the overall Permit area. However, there are no 

known minerals (other than uranium), or oil, gas or coal resources in the Permit 

Area proposed for mining or development. Thus, the direct and indirect impacts 

of the Project to minerals and energy development are negligible. If potential 

projects were to arise, it is expected that coexistence and conflicts would be 

negotiated and agreed upon between the different mineral rights owners, surface 

owners, and land management agencies. 

The NRC, in Section 4.2.1.1 of the SEIS, acknowledges that other mining 

activities would not be able to occur while the project is underway. However, it 

also states that there are no current projects or potential projects to mine coal, oil, 

or gas, and as a result any significant impacts to other mining or resource 

development projects are unlikely (NRC, 2011a). 

Operation 

Impacts to mineral and energy development would be similar throughout the 

Construction, Operation and Reclamation phases of the Project. 

The NRC, in Section 4.2.1.2 of the SEIS, concludes the Operation phase would 

have similar limitations on mineral and energy development as in the 

Construction phase (NRC, 2011a). 

Reclamation 

Impacts to mineral and energy development would be similar throughout the 

Construction, Operation and Reclamation phases of the Project. 

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The NRC, in Section 4.2.1.3 of the SEIS, concludes the Reclamation phase would 

have similar limitations on mineral and energy development as in the 

Construction phase (NRC, 2011a). 

4.2.4.5 Infrastructure 

Construction, Operation, and Reclamation 

As mentioned above, about 345 acres of the 4,254 acres within the Permit Area 

would be disturbed by the construction of facilities such as access roads, utility 

corridors, the Plant, Storage Ponds, wells and mine units. However, 

decommissioning, removal, and surface reclamation is required for all these 

facilities, so they would not become part of the regional infrastructure unless there 

were a specific request by the landowner (the BLM or State of Wyoming) and 

approval was obtained from the BLM and WDEQ-LQD to leave the facilities in 

place to improve post-operational access or land use. 

The only junctions with the regional infrastructure are where the Permit Area 

access roads tie into existing roads and where the transmission line to the Plant 

ties into the existing power line along the western boundary of the Permit Area. 

Required measures for road construction and installation of the transmission line 

are discussed by the resources that could be impacted (e.g., surface water or 

wildlife). 

4.2.5 Land Use Impacts from Other Alternatives 

4.2.5.1 No Action Alternative 

Under the No Action Alternative, there would be no change in current uses. 

4.2.5.2 Other Action Alternatives 

Not Fencing the Pattern Areas would reduce the impacts of the Project on all 

existing land uses, except minerals and energy development. Without fencing, 

livestock, wildlife, and recreationists would not be physically precluded from the 

mine unit pattern areas. However, access to such areas could be hazardous or 

harmful to livestock, wildlife, and recreationists. Additionally, Not Fencing the 

Pattern Areas would decrease the Project’s infrastructure. 

With the exception of infrastructure, the short-term land use impacts from Drying 

Yellowcake On-Site would not be appreciably different than those from the 

Proposed Action. During Construction, an on-site dryer may slightly increase the 

use of roads in the Project Area due to the increased material transport and 

construction activity necessary to build the dryer. However, during Operation, 

use of a dryer would result in fewer shipments from the site due to the difference 

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in volume between yellowcake slurry and dried yellowcake. Therefore, traffic 

necessary for the transport of the shipments and use of the roads would also be 

decreased. 

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4.3 Transportation 

4.3.1 Agency Required Measures 

The required environmental protection measures are summarized below from 

Sections OP 2.6 and RP 3.2 and 4.4 of the WDEQ-LQD Permit to Mine (LCI, 

2011b) and Sections 2.1.1.1.2.3 and 2.1.1.1.5.4 of the NRC SEIS (NRC, 2011a). 

4.3.1.1 Road Installation or Improvement 

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

a series of steps for route selection, road design, and construction practices to help 

ensure the roads are located to minimize disturbance and are appropriate for the 

traffic load. Roads would be built in accordance with BLM guidance found in 

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

(1996a) and erosion would be mitigated according to the SWPPP (Attachment 

ADJ-3 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). 

4.3.1.2 Road Maintenance 

Maintenance costs for the county roads could accrue to both Carbon and 

Sweetwater Counties, although most Project revenues would be generated in 

Sweetwater County. LCI is working with the Counties to develop agreements for 

maintenance of roads accessing the Permit Area. 

If not already done prior to BLM approval of the proposed action, LCI would 

prepare and submit a Road Use Maintenance Agreement for Sweetwater County 

review and approval. The Agreement would comply with the standards and 

conditions of the Sweetwater County Public Works Director, the Sweetwater 

County Attorney's Office, and the Sweetwater County Board of County 

Commissioners, and would address roadway maintenance, surfacing, dust control, 

weight limits, traffic, snow removal, improvements, and related topics. In 

addition, LCI would obtain the necessary Access Permit or License from the 

Sweetwater County Department of Engineering for any crossing, access to, or use 

of a Sweetwater County Road right-of-way. 

4.3.1.3 Road Removal 

Per the requirements of the Reclamation Plan in the WDEQ-LQD Permit to Mine 

(LCI, 2011b), removal of roads is required upon Project completion. If a 

landowner specifically requests that a road (or structure) be left in place, then it is 

generally possible to revise the Permit to accommodate that request. However, 

the existing Permit language specifies road removal, and the reclamation bond for 

the WDEQ-LQD Permit to Mine includes costs for road removal. Improved or 

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constructed roads would be reclaimed by removal of culverts, removal of road 

surfacing and road bed materials, and recontouring, as necessary. Unimproved 

roads would be recontoured, if necessary, and scarified, ripped, or disced to 

reduce compaction. The roads would then be reclaimed through preparation of 

the seed bed and reseeding, in accordance with the Permit requirements. 

4.3.1.4 Safety 

In the application for NRC licensing, LCI submitted the transportation logistics to 

the NRC, who determined that the transportation and associated safety measures 

were adequate. All transportation activities associated with the project would 

adhere to existing transportation regulations, including those found in 10 CFR 

Part 71 (NRC, 2004) and 49 CFR 171-180 (USDOT, 2005). An emergency 

response manual would be available in the event of an accident involving vehicles 

transporting radioactive materials. Any non-radioactive chemical spills would be 

reported to the State environmental agency, USEPA, and USDOT. Additionally, 

several measures would be taken in order to reduce the potential for accidents. 

These include: 

 All delivery truck drivers would hold appropriate licenses and 

certifications, and submit to a mandatory drug testing program; 

 All delivery trucks used to transport Project materials would carry the 

certifications of the relevant safety inspections; 

 Speed limits would be at 30 miles per hour or less, and an active driver 

safety and accident avoidance program would be carried out; 

 On-site and local roads would be plowed, maintained, and improved as 

appropriate; and 

 An internal report would be filed in the case of a near-miss or accident, 

and drivers would be briefed on how to avoid similar future incidents. 

4.3.2 Transportation Monitoring 

Records of on-site road maintenance would be kept along with records of 

shipping and receiving goods, driver training, and truck safety certifications. 

Inspections would also be performed quarterly, at a minimum, to examine the 

condition of the road surface and culverts to maintain the quality of the road for 

safe transportation. On-site fuel storage tanks would be examined weekly to 

check for leakage and spills from the tank to reduce any impacts that could be 

associated with such chemical leakage. LCI would also install traffic counters on 

the smaller, improved surface roads for which no data currently exists to help 

determine Greater sage-grouse impacts, as described in Attachment OP-6 of the 

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

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4.3.3 Impact Significance Criteria 

Transportation impacts are evaluated on the relative increase in traffic levels and 

whether the increase would degrade safety conditions. The impacts of the 

transportation on specific resources are evaluated in the respective resource 

sections (e.g., the impacts on wildlife are discussed in the Section 4.9). 

4.3.4 Transportation Impacts from the Proposed Action 

Potential impacts to transportation could occur throughout all phases of the 

Project. Table 4.3-1 includes an estimate of the number and size of vehicles that 

would be needed during the life of the Project. It is anticipated that traffic would 

usually be equally divided among the three primary routes to the Permit Area 

(Figures 4.3-1 and 4.3-2): 

 From Rawlins via US 287 to the Minerals Exploration Road and Sooner 

Road; 

 From Casper via WY 220 to the Bairoil Road and Sooner Road; and 

 From Rock Springs via I-80 to the Wamsutter Crooks Gap Road. 

Traffic could also come from Lander via US 287 to the Wamsutter Crooks Gap 

Road, but this was assumed to be a less-used route. 

Transportation could be affected by the Proposed Action due to increased traffic 

on existing roads and, in turn, potential increases in traffic-related accidents. 

However, with the required road construction and maintenance practices, 

transportation conditions both outside and inside the Permit Area are not 

anticipated to result in any different traffic accident rates than are typical for 

Wyoming. Specific conditions during Construction, Operation, and Reclamation 

are discussed in the following subsections. 

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4.3.4.1 Construction 

Improvements to the existing East and West Access Roads would be necessary in 

the earliest stages of Construction to provide adequate access for personnel, 

equipment, and materials. The equipment and materials would be general 

construction materials and the ISR-specific equipment (e.g., ion exchange resin 

tanks). Most of the initial Construction activities would be concentrated at the 

Plant, although installation of secondary roads to the deep wells would be 

necessary prior to drilling of the wells. It is anticipated that the deliveries of 

larger equipment (e.g., tanks) would come in by truck from the manufacturers, 

traveling on the Wamsutter Crooks Gap Road and that the rest of the traffic 

to/from the Permit Area would be equally divided among the three routes to the 

site. 

Comparison of existing and additional traffic volume (Tables 3.2-1 and 4.3-1) 

indicates the increased volume during initial Construction would not be noticeable 

on any of the major transportation routes. The increased traffic volume might be 

noticeable on WY 73, on which the volume would increase by five to ten percent 

during the seven months of initial Construction. 

During Construction for Mine Unit Development, secondary access roads would 

be built to connect the header houses within a mine unit and connect the mine unit 

to the Plant. Two-track roads would provide access to the wells in the monitor 

ring, with local improvements if needed to prevent erosion (e.g., gravel surface to 

prevent creation of a mud hole in a low spot). These roads would remain in place 

until removed and reclaimed during Mine Unit Reclamation. On-site traffic 

during the Mine Unit Development would include movement of equipment and 

associated personnel, such as moving rigs from well to well during pattern 

installation. 

Section 4.3.1.1 of the NRC SEIS describes the changes in transportation expected 

during the Construction phase of the Lost Creek ISR project, including 

transportation of workers and materials to and from the site. Potential impacts 

included in this analysis are dust, emissions, noise, increased traffic on main 

roads, and the potential for accidents. However, the increase in traffic is expected 

to be small, therefore making the potential impacts small as well (NRC, 2011a). 

4.3.4.2 Operation 

Maintenance of the East and West Access Roads would continue throughout the 

Operation phase. During the Operation phase, the overall volume of traffic would 

decline (Table 4.3-1). The number of vehicles used by personnel commuting to 

and from the Permit Area during the Operation phase is estimated to be about half 

that during Construction. As noted in the table, some equipment would be 

brought to the site and then remain on-site for the duration of the Project. Other 

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equipment and materials would be transported to and from the Project on a 

regular basis, including shipments of: 

 Supplies to the Plant, including potable water, office supplies, CO2, 

oxygen, diesel fuel, gasoline, salt, soda ash, sulfuric acid, hydrogen 

peroxide and drilling mud. Most of these supplies would be delivered to 

the Plant, although some supplies would be delivered to the staging areas 

for use in the mine units; 

 Shipments of yellowcake slurry from the Plant to a toll drying facility; and 

 Shipments of waste material to be disposed of off-site. 

On-site traffic during the Operation phase would include regular, periodic 

movement of personnel, such as travel around an operational monitor ring for 

sampling once every two weeks. 

The NRC SEIS describes the changes in transportation expected during the 

Operation phase of the Lost Creek ISR project in Section 4.3.1.2. These impacts 

include transportation of workers and materials to and from the site, particularly 

the radioactive materials the result from the process. Potential impacts included 

in this analysis are dust, emissions, noise, increased traffic on main roads, and the 

potential for accidents, specifically involving vehicles transporting the radioactive 

materials. However, due to low increase in traffic and the management practices 

put in place to provide safe transport, the potential impacts are expected to be 

minimal (NRC, 2011a). 

4.3.4.3 Reclamation 

During reclamation of each mine unit, all of the secondary and tertiary roads 

associated with that mine unit would be removed and reclaimed, unless needed 

for access to another mine unit. During Reclamation, all remaining on-site roads 

would be removed and reclaimed; although before the on-site roads are reclaimed, 

the surface management agency (primarily BLM), would be consulted and given 

the option to retain the roads established for the Project. The impacts on traffic 

during the Reclamation of the Project are expected to be similar to those incurred 

during Construction, although the overall volume would be less. In addition, 

rather than the majority of truck traffic consisting of deliveries to the site, the 

majority of the truck traffic would consist of removal of materials from the site 

either for reuse, recycling, or disposal. 

The NRC SEIS (Sections 4.3.1.3 and 4.3.1.4) addresses transportation during the 

reclamation phase by recognizing that there would be more larger trucks used 

during decommissioning, but the relative impacts to transportation in the area 

would be insignificant on main roads and minimal on smaller roads (NRC, 

2011a). 

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4.3.5 Transportation Impacts from Other Alternatives 

4.3.5.1 No Action Alternative 

Under the No Action alternative, current access, uses, and maintenance would 

continue. 

4.3.5.2 Other Action Alternatives 

The impacts of other alternatives (Not Fencing the Pattern Areas and Drying 

Yellowcake On-Site) on transportation would be similar to those for the Proposed 

Action. If the pattern areas were not fenced, the potential for personnel to cut 

across open areas could increase; however, the measures for topsoil and 

vegetation protection (Sections 4.5 and 4.8) are intended to reduce this potential 

with or without the pattern area fences. If a dryer were installed on-site, the 

number of shipments of yellowcake would be reduced from about one shipment 

every five days to about one shipment every 15 days. There would be a 

corresponding decrease in impacts, although the overall effect would be minimal. 

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4.4 Geology 

4.4.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Sections OP 3.3 through 3.6, and RP 3.1 of the WDEQ-LQD Permit to Mine 

(LCI, 2011b) and Sections 2.1.1.1.2.1 and 2.1.1.1.5.5 of the NRC SEIS (NRC, 

2011a), and Condition 10.5 the NRC License (NRC, 2011b). 

To prevent unanticipated impacts to the subsurface materials, wells would be 

constructed in accordance with appropriate designs for their use, tested at required 

intervals, and operated in accordance with calculated injection pressures. These 

construction and operation requirements are included in Sections OP 3.3, 3.4, and 

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

With respect to future subsurface activities, all the Project wells would be 

abandoned in accordance with applicable requirements. The abandonment 

requirements for the mine unit and water supply wells are listed in Section RP 3.1 

of the WDEQ-LQD Permit to Mine, and the requirements for the UIC Class I 

wells are in Attachment J of the WDEQ-WQD application, which is included in 

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

notice of the presence of the abandoned wells is also required via a deed notice 

and/or individual well markers (WDEQ-LQD NonCoal Rules, Chapter 11, 

Section 8(h) [WDEQ, 2005b]). 

To prevent unanticipated impacts from geologic conditions, in particular 

earthquakes, facilities would be constructed on appropriately prepared surfaces 

and in accordance with applicable building codes. Pressure monitoring, leak 

detection, and similar measures would provide information of adverse effects 

from any ground movement, and automatic shut-offs would allow for prevention 

and minimization of leaks. (This equipment is described in detail in Sections OP 

3.5 and 3.6 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). 

4.4.2 Monitoring of Geologic Impacts 

To ensure formation fracture pressures are not exceeded, injection pressures and 

flow rates for the mine unit production and injection wells would be monitored as 

detailed in Section OP 3.6 of the WDEQ-LQD Permit to Mine and reported in the 

Annual Report submitted to NRC and WDEQ. Similarly, injection pressure, flow 

rate, and annulus pressure in the UIC Class I wells would also be monitored and 

reported in accordance with the requirements of the UIC Class I Permit, and an 

evaluation of the well performance would be included in the Annual Report 

submitted to NRC and WDEQ. 

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Should an earthquake of unusual intensity occur, a program of well testing, such 

as MITs or using down-hole cameras, could be implemented to ensure subsurface 

damage to the wells had not occurred. 

4.4.3 Impact Significance Criteria 

The criteria used to evaluate impacts to geology, e.g., subsidence, are the 

likelihood of an impact occurring, and, if it did occur, what the magnitude and 

consequences would be. In addition, the impacts from geologic conditions, i.e., 

geologic hazards such as earthquakes, on the Project were evaluated. 

4.4.4 Geologic Impacts from the Proposed Action 

The potential impacts to geology from the Proposed Action are limited to impacts 

during Construction and Operation. Impacts from geologic conditions could 

occur throughout the life of the Project. 

4.4.4.1 Construction 

Initial Construction 

There are no bedrock outcrops in the Permit Area, and drilling logs indicate that 

bedrock is a few feet below the surface. Earth moving during Construction would 

not disturb bedrock formations at depth, e.g., pipeline burial depths and key cuts 

for the pond embankments are less than six feet. Based on the results from 

geotechnical borings completed in the vicinity of the Plant, no extraordinary 

measures are needed to stabilize building foundations. The results of the 

geotechnical drilling and recommendations and requirements for building site 

preparation are included in Attachment OP-7 of the WDEQ-LQD Permit to Mine 

(LCI, 2011b). 

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

installed in 2008 to provide the necessary subsurface data to determine the 

feasibility of using deep wells for waste disposal. Based on the information 

obtained from that well, well completions in the target interval of the Fort Union 

Formation would not impact the subsurface geologic conditions. In particular, 

hydraulic fracture treatments are not considered necessary to provide sufficient 

injection capacity. (Impacts to the water quantity and quality in the Fort Union 

Formation are discussed in Section 4.7.) With respect to geologic hazards, no 

unanticipated conditions, such as an unknown fault, were discovered during 

drilling of the deep well. 

An earthquake could potentially damage a facility, such as a building, under 

construction because the structural integrity of the facility would be less during 

construction than when completed. However, given the relatively low probability 

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of an earthquake of sufficient magnitude to cause damage (Section 3.3), this is an 

unlikely scenario. 

The above assessment is in general agreement with that in the NRC SEIS. (In the 

NRC SEIS, geology and soils impacts are included in the same section; this was 

not done in this EIS because of the importance of topsoil salvage and protection to 

ensure adequate surface reclamation.) Section 4.4.1.1 of the NRC SEIS, states 

that no rock matrix would be altered during this project; therefore, there would be 

little to no subsidence, and the overall impact of the Construction phase is 

minimal (NRC, 2011a). 

Mine Unit Development 

Impacts on geology during Mine Unit Development would be the result of drilling 

to further delineate the ore body and to install wells within the mine units. Drill 

pit and trench excavation would not impact the geology because the pits would be 

relatively shallow (ten feet deep or less). Drilling would have a direct albeit 

minor impact on the geology due to the removal of subsurface materials as a 

result of the drill bit cutting action. However, the amount of material removed 

from the subsurface formations (sandstones, siltstones, and shales) would not be 

sufficient to impact the structural integrity of the formations. In addition, 

pressures used during drilling are not sufficient to adversely impact subsurface 

conditions. 

A beneficial impact of Mine Unit Development, which would occur during 

aquifer testing (and is one of the purposes of the aquifer testing), would be 

location of improperly abandoned wells from previous exploration. Efforts are 

made before Mine Unit Development to locate old drill holes, but records of all 

prior drilling locations may not exist or it may not be possible to locate all of the 

old drilling locations to check abandonment methods. If an improperly 

abandoned drill hole is found during aquifer testing, it would be abandoned in 

accordance with the permit requirements. Additional information is included in 

Section D5.2.4.1 in Appendix D5 of the WDEQ-LQD Permit to Mine (LCI, 

2011b). 

4.4.4.2 Operation 

Potential impacts of the Operation phase to the subsurface geologic conditions are 

discussed below. No impacts from geologic hazards are anticipated during 

Operation, other than the existing potential for earthquakes. 

Future Resource Development 

Removal of uranium from the target sandstones would result in a permanent 

change to the composition of these sandstones, which is a direct and permanent 

impact to the geology of the Permit Area. However, the impacts would not 

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preclude recovering other minerals that might be discovered in economic 

quantities within the Permit Area in the future. 

Injection and Production Rates and Pressures 

In the uranium production formation, no significant matrix compression or ground 

subsidence from injection or pumping of fluids is expected. Injection pressures 

are calculated to ensure fracture formation pressures are not exceeded, and 

pumping rates are balanced with injection rates and are calculated to be 

sustainable. The net withdrawal of fluid (bleed) would typically be one percent or 

less. Once groundwater restoration is complete, groundwater levels would 

approximate pre-operational levels. 

Theoretically, changes to the aquifer pressure may impact the transmissivity (e.g., 

resistance to flow) of the Fault. The pressure of the produced aquifer would be 

increased locally at the injection wells and decreased locally at the production 

wells during Mine Unit Operation and Restoration activities. Overall, the 

pressure of the aquifer will be decreased because more water is being removed 

than is being injected (bleed). It is very unlikely that the planned ISR operations 

would reactivate the Fault, and extremely unlikely that any earthquakes would be 

generated. Documented cases where fluid withdrawal or injection has impacted 

fault transmissivity or resulted in earthquakes have occurred when the change in 

reservoir pressure was on the order of 1,000 to 5,000 psi or higher. Operations at 

the Permit Area are expected to induce much lower pressure changes, in the range 

of 50 to 150 psi. 

In the deeper formation in which the Class I wells would be completed, injection 

pressures are also calculated to ensure fracture formation pressures are not 

exceeded. As with the shallower uranium production formation, the pressure 

changes would be less than those in the documented cases of earthquakes or 

changes in fault transmissivity. 

Matrix Effects 

The uranium mobilization and recovery process in the target sandstones does not 

result in the removal of rock matrix or structure. Rather, the lixiviant mobilizes 

uranium that was deposited within the sandstone long after the sands were 

deposited and lithified (Section 2.1.2 of the NRC GEIS [NRC and WDEQ, 

2009]). The lixiviant is selected to optimize dissolution of the uranium mineral 

coatings on sediment grains in the target sandstones and minimize potential 

interference with the host formation (Section 2.4.1.1, NRC GEIS [NRC and 

WDEQ, 2009]). This assessment is in agreement with that in Section 4.4.1.2 of 

the NRC SEIS (NRC, 2011a). 

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4.4.4.3 Reclamation 

No impacts would occur to the geology of the Permit Area during Mine Unit 

Restoration or Reclamation. The wells in the mine units would be abandoned, but 

the pressures used for well abandonment are similar to those for well 

construction. This assessment is in agreement with that in Section 4.4.1.3 of the 

NRC SEIS (NRC, 2011a). 

During Final Reclamation, decommissioning, facility removal, topsoil placement 

and revegetation would occur. These activities would have no impact on the 

geology in the Permit Area. Abandonment of the deep wells would be done in 

accordance with the UIC Class I Permit. 

4.4.5 Geologic Impacts from Other Alternatives 

4.4.5.1 No-Action Alternative 

Under the No-Action Alternative, the Project would not go forward and there 

would be no changes to the geologic conditions in the Permit Area or in the 

surrounding region. Existing land use activities that could potentially impact the 

geology (such as mineral and oil and gas drilling) would still occur. Existing 

wells would be plugged but this would not have an additional impact on the 

geology. 

4.4.5.2 Not Fencing the Pattern Areas 

Under this alternative, the pattern areas would not be fenced. This alternative 

would have no impacts on the geology. Geologic hazards would not impact this 

alternative. 

4.4.5.3 Drying Yellowcake On-Site 

This alternative would have no impact on geology. The dryer would be within the 

Plant, so the measures taken to prevent impacts from geologic hazards on the onsite facilities, e.g., construction in accordance with appropriate building codes, 

would be in place, as well as applicable procedures for spill control should 

unanticipated damage occur. 

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4.5 Soils 

4.5.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Sections OP 2.5, OP 2.9, OP 3.5, RP 3.3, and RP 4.5 of the WDEQ-LQD Permit 

to Mine (LCI, 2011b), Section 7.5.2 of the NRC Technical Report (LCI, 2010), 

Sections 2.1.1.1.2.1, 2.1.1.1.4.4, 2.1.1.1.4.5, 2.1.1.1.5, and 6.2.2 of the NRC SEIS 

(NRC, 2011a), and Conditions 11.6 and 12.13 of the NRC License (NRC, 2011b). 

The following measures would be put in place to minimize the amount of topsoil 

disturbed (Table 4.5-1), ensure suitable material is used to replace the same depth 

of material after removal, and minimize erosion and compaction of soils. 

4.5.1.1 Disturbance Minimization 

Site selection for all facilities would take into account the protection of 

environmental features, such as vegetation and topsoil, as well as safety, cost, and 

efficiency of operation (Section OP 2.5.2.2 of the WDEQ-LQD Permit to Mine 

[LCI, 2011b]). Topsoil would be removed in situations where it cannot be 

protected from loss of the soil resource unless it is removed, such as underneath 

buildings; topsoil would also be removed from a monitor well road (or portion of 

the road) if the road must be upgraded to maintain its integrity. 

Topsoil would not be stripped from areas where there is minor disturbance, such 

as light-use-roads, fences, and monitoring stations (such as the meteorological 

station (Section 3.10). In the pattern areas and in the monitor well ring, topsoil 

would not be removed except at the excavated mud pits, unless it is determined 

that use of a portable mud pit and disposal of the drill cuttings at an alternate 

location would be preferable. 

4.5.1.2 Appropriate Excavation, Storage, and Replacement 

Topsoil removal would be supervised by a qualified person using detailed soil 

survey data, which would be field checked. Based on the detailed soil surveys 

and field experience to date, the upper materials that would be salvaged can be 

readily distinguished from the lower materials. Topsoil surveys and anticipated 

stripping depths for areas of the Plant, supporting facilities, and Mine Unit 1 are 

included in Section 3.4. Surveys for future mine units would be included as part 

of the Hydrologic Plan and Report for each unit (Section 2.1.1). As a field check 

along roadways and pipelines, LCI would dig pits at intervals where changes in 

stripping depths are anticipated to help ensure the most productive portion of the 

soil profile is salvaged. 

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Excavated soils would be stockpiled or windrowed to protect them from wind and 

water erosion and from impacts due to site activities, e.g., traffic. All long-term 

topsoil stockpiles would be labeled and inspected periodically. These stockpiles 

would be sloped on all sides to a slope of no greater than 3:1 and would be 

reseeded with the approved permanent seed mixture (Table 4.8-1), minus shrub 

specie(s), at the next appropriate season after the stockpile is created. As an 

alternative, the topsoil stockpile may be seeded with a rigorous certified weed free 

annual cover crop such as sterile rye grass or millet in order to establish a cover 

on the topsoil pile. A seed drill would be used to the extent possible, however, 

when slopes dictate, seed may be broadcast and racked in by hand. Topsoil 

stockpiles would generally be located north or east of roads so they do not serve 

as snow fences. Locations of the long-term stockpiles are noted in Table OP-2a 

of the WDEQ-LQD Permit to Mine (LCI, 2011b). Other measures, including toe 

ditches, would also be used to minimize wind and water erosion. (Additional 

information on short-term and long-term topsoil stockpile protection is included 

in Section OP 2.5 of the WDEQ-LQD Permit to Mine [LCI, 2011b].) 

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

excavated; unless, the area from which the soils were excavated is approved for a 

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

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

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

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

historic exploration activities), if such replacement is approved by WDEQ-LQD. 

Prior to replacement of soils from long-term stockpiles, the soils would be 

sampled for fertility and the sampling results compared to the baseline results. If 

necessary based on the sampling results, soil amendments or changes to the soil 

reapplication or seeding practices would be proposed to the BLM and WDEQLQD ensure the topsoil is sufficiently productive for successful revegetation. 

Replaced soil thicknesses would correspond to depths and acreages salvaged 

during Construction. The replacement would be along contour, where necessary 

to prevent soil erosion. To avoid clods, soils would not be replaced when the 

ground is wet or frozen. The replaced topsoil would be disced to create a proper 

seed bed. (Section RP 4.5.3 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). 

4.5.1.3 Erosion and Compaction Minimization 

Soil loss from wind erosion would be controlled by removing vegetation only 

where necessary, and by techniques that may include surfacing roads with gravel, 

limiting traffic speeds, watering unpaved roads, spreading soil binding agents, 

mulching, inclusion of wind breaks, and timely reclamation. Soil loss from water 

erosion would be reduced by timely reclamation, installing drainage controls and 

sediment trapping structures, and reseeding and installing water bars across 

reclaimed areas. 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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To stabilize soils and support the ecosystem, vegetation would be established at 

disturbed areas as soon as conditions allow. For short-term disturbances during 

the life of the Project, such as pipeline installation, the temporary or permanent 

seed mix may be used, depending on the time of seeding and the erosion risk. For 

Reclamation, the permanent seed mix would be used. The permanent seed mix 

was approved by the BLM Rawlins Office on January 14, 2010 and WDEQ-LQD 

(Section RP 4.5.4 of the WDEQ-LQD Permit (LCI, 2011b). The temporary seed 

mix would be a rigorous certified weed-free annual cover crop, such as sterile rye 

grass or millet. 

The negative effects on soil properties resulting from the high volume and degree 

of constant activity at the Permit Area would be minimized where possible. Soils 

compacted during construction and operational activities would be disced and 

seeded as early as possible following use. Vehicular traffic would be minimized 

and restricted to specific routes. In particular, traffic routes would be established 

within mine units. This would reduce the occurrence of compacted soils. 

4.5.1.4 Soil Contamination Prevention 

Tank containments would be designed to prevent releases to soil from tank 

failure. Pipelines would be buried five to six feet below ground surface (i.e., 

below the frost line) and constructed of a corrosion-free HDPE material. Mine 

unit and pipeline flow and pressure would be continuously monitored during 

Operation to ensure timely detection of any releases from pipeline breaks or 

ruptures. An automatic shutdown system would be installed to limit the volume 

of such releases. To minimize potential impacts from accidental spills, LCI 

would develop and implement a Spill Prevention, Control, and Countermeasure 

(SPCC) plan. The SPCC plan would include directions on spill prevention 

inspection, accidental discharge reporting procedures, spill response, and cleanup 

measures. 

Prevention and remediation of accidental releases, which could potentially 

contaminate soils, would be enacted as described in Section OP 2.9 of the 

WDEQ-LQD Permit to Mine (LCI, 2011b). Measures would be taken to ensure 

the operational safety and integrity of pipelines, fittings, valves, tanks, wells, 

buildings, Storage Ponds, and fuel storage areas. Additional practices for the 

minimization of spills are described in Section 7.5.2 of the NRC Technical Report 

(LCI, 2010). 

4.5.2 Monitoring of Soil Impacts 

Regular inspection of topsoil removal practices, erosion controls, topsoil 

stockpiles, reapplication practices, and reclamation/revegetation status would be 

conducted to ensure that soil protection measures are working properly. 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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4.5.3 Impact Significance Criteria 

The criteria used to evaluate soil impacts are both quantitative and qualitative. 

For evaluating soil disturbance, the amount of topsoil that would be disturbed has 

been estimated, and the actual disturbance would be evaluated against that 

estimate to ensure it is not substantially exceeded. In order to adequately restore 

soil, it would be necessary to assess that the same depth of material is placed after 

removal. Furthermore, the material used to replace the disturbed soils would need 

to be suitable, viable topsoil in order to ensure vegetative success after 

reclamation. Finally, success in stabilizing topsoil and minimizing erosion would 

be evaluated. 

4.5.4 Soil Impacts from the Proposed Action 

Total short-term and long-term acreage of soil disturbance and amounts of 

removal and stockpiling of topsoil were estimated for the life of the Project. For 

purposes of topsoil removal, short-term was defined as a few days to a few 

months, while long-term was defined as the duration of the Project. Long-term 

disturbances would occur with the construction of buildings, which would exist 

for the life of the Project, e.g., under the Plant, and the area would only be 

reseeded during Final Reclamation, after the facilities are removed and topsoil 

replaced. Short-term disturbance would occur in areas where topsoil would be 

removed, but topsoil would be replaced shortly after the disturbance, and the area 

would be reseeded to reestablish vegetation for erosion control (e.g., pipeline 

installation during Mine Unit Development and pipeline removal during Mine 

Unit Reclamation). 

Table 4.5-1 shows the estimated acreage for topsoil stripping and vegetation 

disturbance. The location of the soils with respect to Project infrastructure can be 

seen in Figure 3.4-1. It was estimated that a total of approximately 72 acres and 

231,295 cubic yards of topsoil could potentially be removed and stockpiled on a 

short-term basis and a total of approximately 103 acres and 332,238 cubic yards 

of topsoil could potentially be removed and stockpiled on a long-term basis 

(Table 4.5-1). However, as outlined below, this soil disturbance is progressive, 

i.e., it does not all occur in the Initial Construction phase. 

Soils could also have the potential to erode if improper construction or excavation 

design were enacted. Also, the possibility of spills could potentially cause soil 

contamination; however, both of these impacts are expected to be minimized by 

the protective measures in place (Section 4.5.1). 

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Table 4.5-1 Vegetation and Topsoil Disturbance (Page 1 of 4) 

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Table 4.5 1 Vegetation and Topsoil Disturbance (Page 2 of 4)

- Table 4.5-1 Vegetation and Topsoil Disturbance (Page 2 of 4) 

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Table 4.5-1 Vegetation and Topsoil Disturbance (Page 3 of 4)

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Table 4.5

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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4.5.4.1 Construction 

During Initial Construction, principal impacts on soils would result from earthmoving activities associated with construction and excavation of the Plant, 

staging areas, the five deep wells and associated pipelines (some of which might 

not be installed or installed later), the trunkline (which would actually be 

constructed in stages as the mine units are brought on-line); and the access road 

improvements. 

The soil impacts depend on the number of acres disturbed, the type of 

disturbance, and the time period of disturbance. The amount of long-term topsoil 

removal and stockpiling during Initial Construction is on the order of 61 acres and 

195,210 cubic yards. The amount of short-term topsoil removal and stockpiling 

during Initial Construction is on the order of 33 acres and 107,018 cubic yards 

(Table 4.5-1). 

During Mine Unit Development, surface disturbance would result from activities 

related to development of new mine units, which includes drilling of injection, 

production and monitor wells, and construction of pipelines, header houses and 

necessary access roads. The impacts would be similar to those discussed above, 

but the facilities being constructed would be smaller, e.g., header houses, and the 

facilities would be in place for the life of the mine unit, but not the life of the 

Project. For the purpose of determining the acres of soil disturbance during 

Construction, the mine unit facilities are listed below and in Table 4.5-1: 

 pipelines outside the pattern areas; 

 drill pads outside the pattern areas (This includes exploration holes and the 

monitor well rings. The MU1 monitor wells were installed in 2006 to 

2008 to obtain the necessary subsurface information for permitting the 

Project. The surface disturbance associated with those wells is still 

included in this estimate.); 

 secondary and two-track roads to and within the mine units; and 

 pattern areas. 

The amount of long-term topsoil removal and stockpiling during the Mine Unit 

Development phase for the HJ Horizon is on the order of 43 acres and 137,027 

cubic yards. The amount of short-term topsoil removal and stockpiling during 

Mine Unit Development is on the order of 39 acres and 124,276 cubic yards. 

Based on available information, the underlying KM Horizon ore body footprint is 

similar to the HJ Horizon. Therefore, existing roads and pipelines could be used 

to develop the KM Horizon, but additional drilling for monitoring wells and the 

KM pattern area would be needed. The additional area is estimated to be 15 

acres, and assuming topsoil removal would be needed for all of that 15 acres, the 

increased topsoil volume would be about 48,400 cubic yards (Table 4.5-1). A 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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more detailed assessment of the projected surface disturbance related to 

development of the KM Horizon would be available when LCI submits a permit 

revision to WDEQ-LQD. 

Facility development would displace topsoil, which would adversely affect the 

structure and microbial activity of the soil. Loss of vegetation would expose soils 

and could result in a loss of organic matter in the soil. Excavation would cause 

mixing of soil layers and breakdown of the soil structure. Removal and 

stockpiling of soils for reclamation would result in mixing of soil profiles and loss 

of soil structure. However, measures would be taken to ensure that soils are 

properly excavated and stored to maintain topsoil integrity (Section 4.5.1). 

Construction activities have the potential to compact soils. While soils sensitive 

to compaction, such as clay loams, do not exist in the Permit Area, the intense 

volume and degree of constant activity could damage soil properties and cause 

compaction. Compaction of the soil could decrease pore space and cause a loss of 

soil structure as well. This would result in a reduction of natural soil productivity. 

Wind erosion, in addition to what occurs naturally, is also a potential concern at 

the Permit Area. Most of the soils in the Permit Area have a significant 

percentage of sand and silt, which may be more easily eroded than smaller or 

larger particles, depending on site conditions (McCauley and Jones, 2005). Offroad vehicular traffic and construction which would disturb soil and vegetation 

present the greatest threats for increasing wind erosion. Traffic in the Permit 

Area, however, would be restricted (Section 4.5.1), which would minimize 

erosion and compaction impacts. Minimization of the area of disturbance 

(Section 4.5.1.1) and interim and final revegetation (Section 4.8.1) would reduce 

the potential for wind erosion of bare soils. 

Water erosion is not a large concern at the Permit Area due to very low (flat) 

surface slopes, limited amount of precipitation and the lack of perennial and 

intermittent streams. However, removal of vegetation for any activity exposes 

soils to increased erosion. Excavation could break down soil aggregates, 

increasing runoff and gully formation. These impacts would be minimized by 

appropriate drainage designs and excavation techniques (Section 4.5.1). 

Saline soils are very susceptible to soil loss caused by development. Saline soils 

are not common within the Permit Area. Only one of the 28 soil samples 

collected from the Permit Area was slightly saline. 

Surface spillage of fuels, lubricants and other chemicals used during Construction 

could occur at the Permit Area. If not remediated quickly, these materials have 

the potential to adversely impact soil resources. Proper preventative and 

protective practices would help minimize these risks (Section 4.5.1). 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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The NRC SEIS (Section 4.4) concludes that most impacts to the soil would occur 

during the Construction phase, when new infrastructure is being constructed and 

soil is being moved. Due to the small nature of the disturbed soils (less than one 

percent of the total project area), the impacts to the soil are expected to be 

minimal (NRC, 2011a). 

4.5.4.2 Operation 

During the Operation phase, there would be little, if any, new disturbance. Wind 

and water erosion due to loss of vegetation, as well as soil compaction and loss of 

soil structure would still occur, but at a slightly smaller scale compared with those 

in the Construction phase. Protective measures (Section 4.5.1) would be followed 

during the Operation phase as well, thus, minimizing these impacts. 

Surface spillage of process materials (such as barren and pregnant solutions, as 

well as effluents), fuels, lubricants and other chemicals used during Project 

operations could occur in the Permit Area, which, if not remediated quickly, has 

the potential to adversely impact soil resources. However, as mentioned in the 

Construction discussion above, proper preventative and protective practices 

would help minimize these risks (Section 4.5.1). 

Section 4.4.1.2 of the NRC SEIS discusses that the potential for leaks, spills, or 

pipeline breaks could contaminate the soils. However, with the response and 

protective measures in place, there would likely be no long-term impacts to the 

soil (NRC, 2011a). 

4.5.4.3 Reclamation 

Impacts on soil from Reclamation are minimal. During Mine Unit Reclamation, 

disturbance would again occur during some activities, e.g., when wells are 

abandoned and pipelines are removed from reseeded areas. This ‘re-disturbance’ 

of the same areas is not counted twice in the assessment of the acres disturbed. 

During Final Reclamation, short-term, limited impacts could result from 

dismantling process facilities and associated structures, removing buried piping, 

and plugging and abandoning wells. Disruption and/or displacement of existing 

soils would be relatively slight. 

While there may be some short-term impacts as reclamation is in progress, the 

objective of these activities is to return the Permit Area to pre-mining land use. 

Reclamation of disturbed areas (especially long-term disturbance areas) would 

improve soil quality in the Permit Area and offset any adverse impacts. 

Sections 4.4.1.3 and 4.4.1.4 of the NRC SEIS discuss the potential impacts to the 

soil as a result of this project. Similar to Construction, there is soil excavation 

and replacement, however, the purpose of reclamation is to return the land surface 

to its previous condition. Similar to the Operation phase, there is a concern for 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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soil contamination. Due to protective measures and the small scale of the 

disturbed land, impacts to the soil during Reclamation are expected to be minimal 

(NRC, 2011a). 

4.5.5 Soil Impacts from Other Alternatives 

4.5.5.1 No Action Alternative 

The No Action Alternative would result in no change to existing soil conditions at 

the Permit Area or in the region. Surface disturbance would be avoided and the 

area would retain its soil characteristics for the region. Existing land use activities 

(livestock grazing, wildlife habitat, dispersed recreation, minerals and energy 

development, and infrastructure) that impact the soils of the Permit Area would 

still occur. 

4.5.5.2 Not Fencing the Pattern Areas 

There would be only a slight reduction in the soil disturbance if the fences around 

the patterns areas were not constructed. However, the protective measures in the 

pattern areas, specifically reseeding, to reduce erosion risks and maintain topsoil 

viability, would be adversely impacted as the new vegetation growth in the 

reseeded areas would be preferred by livestock and wild horses and less likely to 

take root efficiently. 

4.5.5.3 Drying Yellowcake On-Site 

This alternative would have no impact on soil resources at the Permit Area, as the 

dryer would be within the existing Plant footprint. 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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4.6 Surface Water 

The proposed mine units are in confined aquifers several hundred feet below 

ground surface, and there is no known hydraulic connection between the surface 

of the Permit Area and those aquifers (Section 3.6). Therefore, the discussion of 

hydrologic impacts is separated on the basis of surface water impacts and 

groundwater impacts. 

4.6.1 Agency-Required Measures 

Environmental protection measures to address potential impacts to surface water 

quality include measures to reduce sediment transport and measures to prevent 

and remediate spills and leaks. The required environmental protection measures 

are summarized below from Sections OP 2.9, OP 2.11.1, OP 3.5, Attachments 

OP-2 & OP-4, and Sections RP 3.0 and 4.0 of the WDEQ-LQD Permit to Mine 

(LCI, 2011b), Sections 4.2.5.5, 5.7.1.4, and 5.7.6.6 of the NRC Technical Report 

(LCI, 2010), and Sections 2.1.1.1.2.3 and 2.1.1.1.5.4, 6.2.2, 6.2.4, 6.3.2, and 6.3.3 

of the NRC SEIS (NRC, 2011a). 

Surface disturbing activities would be avoided within 20 feet of the inner gorge of 

the ephemeral channels along with adherence to the Storm Water Pollution 

Prevention Plan Best Management Practices. Ephemeral channels are identified 

on Figure 3.5-1, or determined on-site by qualified field personnel. Site-specific 

engineering and mitigation plans, including ephemeral drainage protection and 

reclamation, may also be required per 43 CFR 3809.411(d)(2). Exception(s) may 

be granted, by the BLM, on a case-by-case basis, within areas that could not 

reasonably be avoided and that would adequately protect identified resources. 

4.6.1.1 Measures Related to Sediment Transport 

The primary measures to address surface water quality impacts related to 

sediment transport would include: 

 limiting soil compaction and removal and protecting excavated topsoil and 

subsurface material from erosion in accordance with Standard Operating 

Procedures (SOPs) and the Spill Prevention Control and Countermeasures 

(SPCC) Plan; 

 ensuring that runoff from disturbed areas meets WYPDES permit 

guidelines for stormwater management and sediment reduction; 

 minimizing well or other facility installation within/near the ephemeral 

channels; and 

 completing appropriate reclamation practices in a timely manner. 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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No unstable surface areas, including areas so defined in the Rawlins RMP 

(landslides, slopes of greater than 25 percent, slumps, and areas exhibiting soil 

creep) are present within the Permit Area. Similarly, no 100-year floodplains, 

perennial waters, springs, wetlands, or riparian areas are present within the Permit 

Area. Ephemeral areas within 100 feet of the inner gorge of ephemeral channels 

may be affected by the Project. The road routes and well locations within a mine 

unit cannot be specifically delineated until the locations of the monitor well ring 

and pattern area within the mine unit are selected based on the delineation of the 

ore body during exploration drilling. If potential travel routes or well locations 

within a mine unit are near ephemeral channels, the BLM hydrologist would be 

contacted to determine if additional protection measures, other than those listed in 

this EIS are necessary. Plans for drainage diversion around the Plant, road 

culverts, and other protection measures are included in Attachment OP-4, Figure 

OP-3c, and related text in Section 2.5, 2.6, and 2.11.1 of the WDEQ-LQD Permit 

to Mine (LCI, 2011b). 

Protection from Compaction/Erosion 

During well development and pump testing, extracted groundwater would be 

discharged to the surface under the provisions of a general WYPDES permit, in a 

manner that mitigates erosion, or would be reused in the drilling process. Soil 

compaction during drilling and pipeline installation can be limited by using 

existing roads to the extent possible. Once a drill site, pipeline route, or facility 

location has been selected, topsoil and subsurface materials would be removed 

and protected in accordance with established procedures to prevent erosion and 

movement of sediment into drainages. To the extent practical, pipe and power line 

installation would occur alongside access roads to limit the overall disturbance 

footprint. When the road is not the shortest path, the utilities would follow the 

most direct path available. Vegetation buffers would be maintained between the 

disturbed area and the drainage whenever possible. The compaction/erosion 

protection measures are described in greater detail in the Section OP 2.5 and 

1.22.1.1 of the WDEQ-LQD Permit to Mine (LCI, 2011b). In addition, runoff 

would be diverted away from exposed soils. There are several practices that 

would mitigate impacts to surface water and ephemeral drainages, including use 

of silt fences, earth dikes, drainage swales, sediment traps, check dams, straw 

bales, construction of water contour bars, application of rip rap, grading and 

contouring, temporary or permanent sediment basins, temporary seeding, 

permanent seeding, mulching, use of geotextiles, sod stabilization, vegetative 

buffer strips, and preservation of mature vegetation, WDEQ-LQD Permit to Mine 

(Sections OP 2.5 and OP 2.11.1.1) (LCI, 2011b). 

Runoff Control 

The physical presence of small facilities (e.g., header houses) are not expected to 

significantly change peak surface water flows because of the relatively flat 

topography of the drainages at the sites, the low regional precipitation, the 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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absorptive capacity of the soils, and the small area of disturbance relative to the 

large drainage area within and adjacent to the Permit Area. However, in areas 

where larger structures (such as the office building and parking lot) may affect 

surface water drainage patterns, diversion ditches and engineered culverts would 

be used to prevent erosion and to control runoff. The drainage control plan for the 

Plant and the road and culvert designs are included in Attachment OP-4 and 

Section OP-2.6 of the WDEQ-LQD Permit to Mine, respectively (LCI, 2011b). 

In areas where runoff is concentrated, energy dissipaters may be used to slow the 

flow of runoff to minimize erosion and sediment loading in the runoff. 

No paved areas are currently planned for the Permit Area. However, if any areas 

are paved, storm water runoff from those areas would be collected by a storm 

water system. The storm water would be temporarily retained in a detention basin 

to reduce the amounts of oils and other pollutants from entering surface water and 

ephemeral drainages. These detention ponds would be designed to control the 

release of storm water runoff at a rate equal to or slightly less than that of the preexploration period. 

The SWPPP (Large Construction General Permit WYR10-0000) would also be 

implemented in accordance with WYPDES requirements. Drainage plans and 

culvert designs are included in the WDEQ-LQD Permit to Mine (e.g., Section OP 

2.6 and Attachment OP-4) (LCI, 2011b). 

Well Placement 

In very rare instances, it may be necessary to install wells in or near an ephemeral 

channel. This would only be done with the authorization of the BLM. If 

approved, the following measures would be implemented to minimize potential 

impacts to the channel. Also see drainage plans and culvert designs included in 

the WDEQ-LQD Permit to Mine (e.g., Section OP 2.6 and Attachment OP-4) 

(LCI, 2011b): 

 installation would be conducted during the dry season; and 

 wellheads would be designed to withstand storm water flows using 

exterior protection measures. (Protection measures may include barriers 

surrounding the wellhead, protective steel casing, cement blocks or other 

means to protect the wellhead from damage that may be caused by runoff.) 

Reclamation 

After short-term disturbances during Construction and Mine Unit Development, 

such as pipeline installation, the disturbed areas would be revegetated with either 

a temporary seed mix or with the permanent seed mix (Sections 4.5 and 4.8). The 

specific reclamation practices are detailed in the WDEQ-LQD Permit to Mine 

(e.g., Sections OP 2.5 and RP 4.5) (LCI, 2011b). 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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4.6.1.2 Measures Related to Spills and Leaks 

The environmental protection measures to prevent and mitigate spills and leaks 

include: selection of appropriate materials for pipelines, wellheads, and tanks; 

proper installation and testing of those materials prior to use; and inspection and 

maintenance. Piping and associated fittings would only be constructed of 

materials that are chemically compatible, able to withstand the expected operating 

pressures, and compatible with ambient conditions. Piping would also be buried 

at sufficient depth (48 to 72 inches below surface) to prevent freezing or pressure 

impacts from the surface. Pipelines and wellheads would be pressure checked 

before being placed into operation and after significant repairs. Automated 

monitoring would be installed so any significant change in flow or pressure is 

detected and operators are notified. Berms, including perimeter and internal 

berms, would be in place in and around the Plant to control the movement of 

spills. Storage tanks for fuels and other liquids will comply with Chapter 17 of 

WDEQ-WQD’s rules and regulations on storage tanks. Each operating mine unit 

would be inspected at least once per day, and the entire Plant also would be 

inspected at least daily when operating. Should a spill or leak occur, remediation 

and reporting procedures have also been developed. The protection measures are 

described in greater detail in the WDEQ-LQD Permit to Mine (e.g., Sections OP 

2.9, OP 3.5, and OP 4.4 and Attachment OP-2) (LCI, 2011b) and with more focus 

on radiological concerns in the NRC Technical Report (e.g., Sections 4.2.5.5, 

5.7.1.4, and 5.7.6.6) (LCI, 2010). 

4.6.2 Monitoring of Surface Water Impacts 

The drainages throughout the Permit Area are ephemeral and flow only in 

response to spring runoff or occasional strong thunderstorms. Because of the 

limited flows, and lack of anticipated impacts, continued surface water sampling 

is not planned except as necessary in response to a specific concern, such as a 

spill. 

4.6.3 Impact Significance Criteria 

The factors identified in the Rawlins RMP were used to assess the significance of 

surface water impacts on the environment (BLM, 2008c). 

 Degradation of water quality beyond the designated use of the 

receiving waterbody, or other violations of federal or state water 

quality standards, or negatively impacting a waterbody listed on 

the State 303d list of Impaired or Threatened Waterbodies. 

 Unmitigated loss of wetlands or wetland function (EO 11990 and 

EO 11988) or activities that would degrade wetland/riparian areas 

such that, as a minimum physical state, proper functioning 

condition and Standards for Healthy Rangelands (USDI-BLM 

1997) are not being maintained. 

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 Streamflow characteristics of perennial streams are altered such 

that established uses by the public and by federal, state, and local 

agencies for fisheries and wildlife and for livestock, recreational, 

municipal, and industrial uses are affected. 

 The alteration of stream channel geometry or gradient by 

accelerated runoff and erosion (e.g., undesirable aggradation, 

degradation, or side cutting) beyond what would be expected by 

natural processes. 

The WDEQ-WQD and LQD criteria were also used to assess the significance of 

surface water impacts on the environment. 

4.6.4 Surface Water Impacts from the Proposed Action 

Because of the limited quantity of surface water within the Permit Area and the 

operational measures that would be taken to avoid impacts to the surface water, 

no impacts are anticipated. However, potential impacts outlined are presented to 

better illustrate the need for the protection measures described in Section 4.6.1. 

The nature and scale of the potential impacts that the Project will have on surface 

water are very similar through all of the three phases (i.e., Construction, 

Operation and Reclamation) of the Project. The surface water impact evaluation 

is, therefore, organized by water quantity (including water use) and water quality. 

4.6.4.1 Surface Water Quantity and Use 

As noted in Section 3.5, perennial or intermittent streams do not exist within the 

Permit Area or on adjacent lands; and there are no surface water use permits 

inside or within two miles of the Permit Area. There are however, ephemeral 

drainages within the Permit Area, which may be affected by erosion. Erosion 

controls would be in place to minimize this impact (Section 4.6.1). 

4.6.4.2 Surface Water Quality 

Potential impacts to the surface water quality in the ephemeral drainages in the 

Permit Area relate to increased sediment transport and spills and leaks. 

Sediment Transport 

The primary surface disturbances associated with ISR operations occur with well 

drilling, pipeline installations, road and facility construction and reclamation 

activities. These disturbances generally involve relatively small areas and have 

short-term impacts, as defined in Section 4.1.3. The larger areas of surface 

disturbance, such as the Plant, would require the diversion of stormwater runoff, 

and culverts would need to be installed under some roads. Without the required 

protection measures, the disturbances and diversions could result in adverse 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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impacts, especially at places where relief is high, due to increased erosion 

potential from surface water runoff and/or due to transport of sediment. Because 

of the low relief across the Permit Area, the ephemeral nature of the drainages, 

and limited precipitation and runoff, the primary areas of concern for sediment 

accumulation are low spots along the roads and drainages where runoff 

accumulates. 

Activities associated with drilling, pipeline installations, and road and mine unit 

construction reduce vegetation cover and soil compaction from heavy machinery 

and frequent traffic. Without vegetation, topsoil is vulnerable to erosion from 

storm events. Soil compaction can result in decreased infiltration rates and 

increased surface runoff, which can increase peak flows and further increase 

surface erosion. Roads to and from the drill sites can become preferential 

pathways for surface water runoff due to compaction and rut depressions. 

Although soil would be stripped from specific areas, such as drill pits and the 

Plant, and stockpiled for replacement during Reclamation, improperly protected 

stockpiles can also erode, increasing sediment loads in surface water runoff. 

During Reclamation, activities, such as discing to loosen compacted soil, could 

result in increased sedimentation to surface water runoff if the increased erosion 

potential were not considered, e.g., discing across the direction of flow. 

The NRC SEIS states that the changes to sediment transport can come from the 

construction activities and vehicular traffic. However, due to the topography of 

the area and the lack of annual surface water, the overall impact on surface water 

quality would be minimal, similar to the assessment in Section 4.6.2 of this EIS 

(NRC, 2011a). 

Spills and Leaks 

Surface water runoff could be impacted due to a spill or leak from wellheads, 

pipelines, or tanks in use during Construction, Operation, or Reclamation. The 

most common accidental release from ISR operations is from breaks, leaks, or 

separations in the piping that transfers mining fluids to and from the Plant and the 

mine units. Failures of fittings and valves at the wellheads, in the header houses, 

at tanks, and other junctions are also a common cause of accidental releases at 

ISR operations. Spill and leak prevention measures would be outlined in the plan 

for Spill Prevention Control and Countermeasures (SPCC). 

The NRC SEIS addresses spills and leaks to surface water in Section 5.1.1. The 

NRC states that the protection and clean-up measures are such that impacts to 

surface waters would be minimal (NRC, 2011a). 

4.6.5 Surface Water Impacts from Other Alternatives 

The No Action Alternative would not generate any additional impacts to the 

existing surface water resources. 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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The Proposed Action includes fencing the pattern area in each mine unit. If the 

pattern areas were not fenced, the potential for soil erosion and subsequent 

sediment in runoff could be slightly increased because of grazing in the pattern 

areas. There would also be a substantial increase in the risk of spills and leaks 

because of livestock damage to wellheads and pipelines. 

No significant differences are expected between the potential impacts from the 

Proposed Action and the other alternatives (Drying Yellowcake On-Site). 

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