4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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4.7 Groundwater 

As described in Section 3.6, groundwater occurs within the Battle Spring 

Formation in a series of relatively flat-lying sandstones. Five distinct uraniumbearing sandstones have been identified in the Permit Area and include, from the 

shallowest to the deepest, the BC, DE, FG, HJ, and KM Horizons. The horizons 

consist of very fine- to coarse-grained arkosic sandstone separated by layers of 

shale, mudstone and siltstone. Groundwater occurs in confined aquifers several 

hundred feet below the ground surface; and there is no known hydraulic 

connection between the surface of the Permit Area and those aquifers. The DE 

Horizon is the first aquifer within the Permit Area, the top of which ranges from 

100 to 200 ft bgs. The depth to the groundwater in the DE Horizon ranges from 

155 feet to over 257 feet. The BC Horizon overlying the DE Horizon is 

unsaturated and separated from the DE Horizon by shale. The HJ Horizon is the 

primary target for the Project and it ranges from 300 to 450 ft bgs. 

4.7.1 Agency-Required Measures 

The required environmental protection measures are summarized below from: 

Sections OP 2.9, 2.11, and 3.0, Attachments OP-2, OP-7, & OP-8, and Sections 

RP 1.0 and 2.0 of the WDEQ-LQD Permit to Mine (LCI, 2011b); Sections 

2.1.1.1.2.4.1 through 2.1.1.1.2.4.3, 2.1.1.1.3.1.1 through 2.1.1.1.3.1.3, 2.1.1.1.4, 

6.2.5, and 6.3.1 of the NRC SEIS (NRC, 2011a); and Conditions 10.1, 10.5, 10.7 

through 10.13, 11.1, 11.3 through 11.6, 12.4, 12.7, and 12.15 of the NRC License 

(NRC, 2011b). References to specific subsections of the WDEQ-LQD Permit to 

Mine are also included. Based on the BLM review of the agency-required 

measures, one additional measure was added. As part of the reclamation plan and 

associated monitoring, required per the BLM 3809 regulations, at least two 

additional stability monitoring samples (Section 4.7.1.1) would be collected, once 

every three months over a six-month period, after the initial stability period. The 

monitoring information would also support combined agency review of current 

stability monitoring requirements (EPA, 2011b). The additional monitoring 

would be required for the protection of livestock, wild horses, and wildlife that 

frequently consume nearby water (Hall, 2009; Davis and Curtis, 2007; NRC and 

WDEQ, 2009; Hall, 2010; Von Till, 2010). 

The discussion of required measures is separated on the basis of on-site and offsite measures because of the different concerns. On-site, the concerns are related 

to conducting Mine Unit Operation and Reclamation as efficiently as possible and 

emphasizing water quality monitoring. Off-site, the concern is related to the 

extent to which on-site groundwater extraction would draw down water levels in 

the four off-site BLM wells. 

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Although not a direct protective measure, the requirement that LCI post a bond 

for site reclamation, including groundwater restoration, provides an assurance that 

the restoration and reclamation activities can be conducted by the permitting and 

licensing agencies should LCI not fulfill its obligations. The bond amount is 

detailed in Table RP-4 of the WDEQ-LQD Permit to Mine (LCI, 2011b). The 

BLM has access to that bond, if necessary, for site reclamation on public lands 

administered by the BLM. 

4.7.1.1 On-Site Required Measures 

Permit Area 

Water from the supply wells would be used as efficiently as possible, and regular 

maintenance would be conducted to check for leaks in the distribution system and 

make the necessary repairs. Leaks would be detected by pressure measurements 

within pipes and by visual inspection. Procedures and training for spill prevention 

and, if necessary, remediation would reduce the possibility of a spill or other 

accidental release that could impact groundwater. A Spill Prevention and 

Response Plan will outline the mitigation steps to follow to prevent spills and 

clean up accidental releases. 

Storage Ponds 

To mitigate the likelihood of pond failure, the two Storage Ponds would be 

designed and built to NRC standards using impermeable synthetic liners. A leak 

detection system would also be installed, and all ponds would be inspected on a 

regular basis. In the event that a problem is detected, the contents of any given 

pond can be transferred to another pond while repairs are made. The proposed 

pond design and operation is discussed in greater detail in Section 2.1.2.2. 

In the event of a detected leak in a Storage Pond, corrective actions would include 

lowering the pond level and locating the leak to allow repairs. Impacts to 

groundwater from a leak associated with the Storage Ponds are remote, since the 

outer pond liner is designed to prevent a release of the pond contents, and the 

depth to the groundwater in the DE Horizon ranges from 155 feet to 257 feet 

below ground surface and separated from the surface by relatively impermeable 

horizons. However if a leak went undetected and the contaminated water reached 

the groundwater in the DE Horizon the impact to groundwater could be high and 

long-term, however any impacts to groundwater would quickly be mitigated since 

regulations require immediate and complete restoration. All pond leaks, causes, 

and corrective actions would be reported to NRC and WDEQ. 

With respect to potential overflow of a pond, operating procedures would require 

that pond levels be closely monitored as part of the daily inspection. Process flow 

to the ponds would be minimal in comparison to the pond capacity, thus 

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facilitating diversion to another pond if necessary. In addition, sufficient 

freeboard would be maintained on the Storage Ponds to allow for a significant 

addition of rainwater with no threat of overflow. Finally, the dikes and berms 

around the Storage Ponds would channel runoff away from the Storage Ponds. 

Pipelines and Related Equipment 

Groundwater impacts from a spill of injection or production solutions from a 

header house or associated piping are unlikely due to the depth to groundwater. 

In addition, any impacts can be prevented by proper design, construction, and 

testing. Pipelines would generally be buried from 48 to 72 inches below the 

surface, minimizing the possibility of freezing in adverse weather and of being 

damaged by surface traffic. In general, piping to and from the Plant and the mine 

units and within the mine units would be constructed of HDPE with butt-welded 

joints or the equivalent. All pipelines and related equipment that would be under 

pressure during Operation would be pressure tested before use. In addition, 

pressures in the pipelines and related equipment are monitored to ensure pressure 

drops or surges do not occur, which could indicate a leak or the potential for well 

or formation damage. Sections OP 3.5 and 3.6.4 of the WDEQ-LQD Permit to 

Mine (LCI, 2011b) contains additional information about leak detection and 

pressure monitoring measures in the mine units. 

Mine Units 

The measures to address impacts from ISR begin before the mine units are 

installed and continues through operation and groundwater restoration. The 

measures include a variety of actions and techniques, including aquifer testing, 

mechanical integrity testing, and reverse osmosis treatment after mining, as 

outlined below. 

Before Construction (Baseline Data) 

A critical initial measure is to ensure the hydrogeologic conditions in a mine unit 

are well understood. Exploration and delineation drilling, geophysical logging, 

and aquifer testing are conducted to ensure undetected high permeability strata, 

geologic faults, improperly abandoned exploration drill holes, and/or 

discontinuous confining units that could allow movement of the lixiviant out of 

the ore zone are identified prior to mine unit operations. Appropriate actions, 

such as additional drill hole abandonment and/or additional monitoring, can then 

be taken to address such conditions. In older ISR operations, this preliminary 

measure was not necessarily conducted as stringently as today. Regulatory 

review of the plans for, and results of, baseline data collection for each mine unit 

is also required through the Hydrologic Test Plan and Report (Section 2.1.2.3). 

Mechanical integrity testing of wells and piping prior to use also reduces the 

possibility of groundwater impacts. The aquifer testing of the mine unit monitor 

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well system also demonstrates that the wells in the monitor well ring can 

efficiently detect excursions and that an excursion can be recovered within a 

specified time. 

During Operation 

Mechanical integrity testing continues during operation, and the schedule for 

monitoring (Section 4.7.2) and actions to be taken should an excursion occur are 

specified in the WDEQ-LQD Permit to Mine and NRC License. For an ISR 

operation, the key to efficient mining and reduction of any potential impacts is the 

balance of production and injection within the pattern area. The design of the 

Project addresses instrumentation and monitoring systems (and review of the 

information from those systems) ensures that the water balance throughout the 

mine units and Plant are working as planned (Sections OP 3.5, 3.6, and 4.0 and 

Attachment OP-2 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). 

If an excursion occurs, appropriate corrective actions would be instituted 

including: conducting a preliminary investigation to determine the probable 

cause; adjusting production and/or injection rates in the vicinity of the excursion 

to generate an effective net process bleed and forming a hydraulic gradient toward 

the production zone; pumping individual wells to enhance recovery of the ISR 

solution, and suspending injection into the pattern area near the excursion, thereby 

increasing the overall bleed rate and the recovery of the ISR solution. Section OP 

3.6.4 of the WDEQ-LQD Permit to Mine (LCI, 2011b) provides more detail on 

excursion response, including evaluation of the ability to control an excursion. 

During Restoration 

The groundwater restoration techniques, including the more traditional techniques 

of sweep, reverse osmosis (RO), and recirculation, and ones that may be used, 

including groundwater transfer, reductant addition, and biorestoration, are 

designed to mitigate groundwater quality impacts from ISR by returning the water 

quality to the uses for which it was suitable before ISR and to applicable 

standards, in accordance with federal and state regulatory requirements. Timely 

application of the restoration techniques and planned monitoring also mitigate 

groundwater quality impacts from ISR and from the restoration activities by 

establishing that the restoration techniques are working as planned and 

determining if adjustments needed. 

Of the restoration techniques, groundwater sweep has the most impact on water 

levels, and to mitigate those impacts, use of alternate techniques, such as 

groundwater transfer, would be used where possible and if they prove as effective. 

During Restoration, the water level changes from would be evaluated to minimize 

interference among the mine units. The vast majority (e.g., on the order of 99 

percent) of groundwater used during Restoration would be treated and re-injected. 

The highest rate of groundwater withdrawal would be on the order of 100 gpm. 

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After it has been determined that uranium recovery is complete in a given mine 

unit the lixiviant injection ceases and the groundwater restoration begins. The 

objective of restoration and reclamation is to return the affected groundwater to 

the pre-operational class-of-use in accordance with WDEQ-WQD requirements 

on the basis of baseline water quality data. Active restoration would take between 

18 to 36 months for each mine unit followed by stability monitoring and 

regulatory approval (Section 2.1.6.3). 

Groundwater Sweep 

During groundwater sweep, water is pumped from the mine unit without 

offsetting with water injection. This pumping creates an influx of baseline quality 

native groundwater into the unit, thereby flushing contaminants from areas 

affected by the horizontal and vertical spreading (flare) of the lixiviant during 

mining. The affected water in the edge patterns of the mine unit is also drawn 

back into more central portions of the pattern area, making the later restoration 

phases more efficient. 

Groundwater produced during sweep would contain uranium and other 

constituents mobilized during production. Initial concentrations of the 

constituents would be similar to those during the later stages of production. With 

enough pumping, constituent concentrations would decline gradually, reflecting 

the influx of baseline quality water. The groundwater produced during sweep is 

treated through the restoration plant ion exchange circuit to capture uranium and 

then either treated with reverse osmosis or pumped directly to disposal. 

Reverse Osmosis Treatment 

RO with permeate injection is used following the groundwater sweep phase. This 

treatment is most effective in returning the concentrations of total dissolved solids 

and trace metals and the aquifer pH to baseline values. 

During this restoration phase, uranium in the groundwater is removed by passing 

the water through an ion exchange circuit. The ion exchange resins remove the 

majority of the soluble uranium in recovered solutions and yield chloride, sulfate 

or bicarbonate ions in the place of the uranium compounds. The chemistry of the 

ion exchange circuit used in the restoration is identical to the chemistry of the ion 

exchange circuit used in the production circuit. Ion exchange resins preferentially 

remove the uranyl dicarbonate and/or uranyl tricarbonate compounds from the 

solution. Chloride, sulfate and/or bicarbonate compounds are displaced from the 

resin and set into the solution. 

After ion exchange, other chemical constituents in the groundwater including 

TDS and trace metals, such as arsenic, molybdenum, selenium, and/or vanadium, 

are removed by passing the water through an RO system. The RO process yields 

two fluids: clean water (permeate) that can be reinjected into the aquifer; and 

concentrated water (brine) that cannot be reinjected directly. Water sent to the 

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RO system usually requires some pre-treatment to prevent fouling of the 

membranes. Commonly, the pH is lowered by addition of sulfuric or 

hydrochloric acid and antiscalant additives may be used. These additives (along 

with the sulfate and/or chloride ions of the acid) are rejected in the RO unit and 

become part of the brine. Therefore, the additives do not become part of the 

permeate which would be injected into the restoration aquifer. After reverse 

osmosis, the permeate may be depressurized to release entrained gasses. This 

process commonly results in a pH increase as carbon dioxide is typically present 

in the permeate and readily released at atmospheric pressure. Sodium hydroxide 

may also be added to increase the pH of the permeate stream prior to injection. 

Groundwater Transfer 

Groundwater transfer (or exchange) involves moving groundwater between a 

mine unit in restoration and another mine unit where uranium production is 

beginning. Both mine units will first have received approval for UIC Class III 

injection. The transferred groundwater may undergo treatment using one or more 

of the permit-approved processes (such as ion exchange, chemical pH adjustment, 

and/or reverse osmosis) prior to injection. Groundwater transfer is generally used 

to replace operationally-affected waters in the restoration mine unit with baseline 

quality water from the production mine unit. The operationally-affected waters 

from the restoration mine unit are then used as the basis for the lixiviant in the 

production mine unit. Because water is transferred (or exchanged) between mine 

units at equal rates, the transfer typically does not generate liquid effluents and 

has the benefit of reducing groundwater consumption. This technique has been 

successfully used at one other ISR operation, and if the opportunity arises to use 

the technique at the Lost Creek Project, it is projected that the transfer will 

involve between zero and two pore volumes. 

Reductant 

If reductant is added to the injection stream during the RO, it would scavenge 

oxygen and reduce the oxidation-reduction potential (Eh) of the aquifer. During 

ISR operations, certain trace elements are oxidized. By adding a reductant, the Eh 

of the aquifer is theoretically lowered, thereby decreasing the solubility of these 

elements. As warranted, hydrogen sulfide, sodium sulfide, or a similar compound 

may be added as a reductant. LCI is more likely to use sodium sulfide as a 

reductant due to the chemical safety issues associated with proper handling of 

hydrogen sulfide. A comprehensive safety plan regarding reductant use would be 

prepared for regulatory review prior to implementation. 

Biorestoration 

Biological reductants may be evaluated as experimental technology, if site 

conditions are suitable for this restoration technology; however, no biorestoration 

will be conducted without prior regulatory approval. 

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Recirculation 

At the completion of RO in a mine unit, recirculation would be initiated. 

Recirculation consists of pumping from the mine unit and re-injecting the 

commingled solution (untreated) into the aquifer it came from. Recirculating 

solution is intended to homogenize the overall groundwater conditions. It is 

anticipated that one pore volume of groundwater would be recirculated. 

Stabilization 

Upon completion of restoration and notification of WDEQ, a stabilization 

monitoring program would begin in which the pattern monitor wells used to 

evaluate restoration success would be sampled. Each pattern monitor well would 

be sampled at the beginning of stabilization and once every three months for a 

period of 12 months, for a total of five samples, and analyzed for the parameters 

listed in Table RP-1b of the WDEQ-LQD Permit to Mine (LCI, 2011b). 

The stability period would be a minimum of 12 months. Following the end of the 

12-month stability period, LCI would perform a regression analysis on each 

monitored constituent within the pattern monitor wells. This statistical method 

would assist in determining if the concentration of a given constituent exhibits a 

significantly increasing trend during the stability period. The regression analysis 

would be performed in accordance with Chapter 17 on trend analyses in the EPA 

guidance document, "Statistical Analysis of Groundwater Monitoring Data at 

RCRA Facilities: Unified Guidance” (EPA, 2009). As part of the reclamation 

plan and associated monitoring, required per the BLM 3809 regulations, at least 

two additional stability monitoring samples (Section 4.7.1.1) would be collected, 

once every three months over a six-month period, after the initial stability period. 

The monitoring information will also support combined agency review of current 

stability monitoring requirements (EPA, 2011b). The additional monitoring would 

be required for the protection of livestock, wild horses, and wildlife that 

frequently consume nearby water (Hall, Susan 2009; Davis, J. A. and Curtis, G.P. 

2007; NRC 2009, Hall, Susan 2010; von Tell, Bill, NRC 2010). 

If a constituent exhibits a strongly increasing trend (or in the case of pH a strongly 

increasing or decreasing trend), the action that LCI would take to resolve this 

situation would depend on the constituent and the status of the restored 

groundwater system. As stated in the EPA guidance document, statistical analysis 

provides a “workable decision framework”. However, due to the complexity of 

the aqueous geochemical groundwater systems involved, these statistical 

techniques should not be relied on as the sole determinant when evaluating the 

effectiveness of groundwater restoration. Therefore LCI would consider which 

constituent(s) is showing an increasing trend in concentration and base the 

decision on further action on the status of the mining zone groundwater 

geochemistry. These actions may include extending the stability period or LCI 

may return to a previous phase of active restoration. The phase of active 

restoration that would be used would be determined by the constituent and the 

process required to decrease its concentration. 

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During stability monitoring, all overlying, underlying and perimeter monitor wells 

would be analyzed for all UCL parameters once every two months. If 

groundwater restoration has not been successful and an excursion occurs during 

stabilization, then the sampling would revert to weekly for affected monitor wells 

until the excursion is resolved. 

If the analytical results continue to meet the appropriate standards for the mine 

unit and do not exhibit significant increasing trends, LCI would submit supporting 

documentation to the regulatory agencies that the restoration parameters have 

remained at or below the restoration standards and request that the mine unit be 

declared restored. 

UIC Class I Wells 

Addressing impacts of the Class I wells begins before the wells are installed and 

continues through operation and reclamation. The initial measures include 

evaluating the target formation for hydrologic properties, characteristics of the 

formation fluids, compatibility of injected and formation fluids. The results of 

these evaluations are included in the WDEQ-WQD UIC Class I Permit, a copy of 

which is included in the WDEQ-LQD Permit (Attachment ADJ-2, LCI, 2011b). 

Regularly scheduled inspections and maintenance, recording and reviewing 

monitoring results, and personnel training to follow established procedures for 

proper operation of the overall disposal system would reduce the possibility of 

damage to a well from overpressuring or other action that could affect the well 

performance. These requirements are also outlined in the Class I Permit, as are 

well abandonment and financial surety requirements. 

4.7.1.2 Off-Site Required Measures 

The water levels in four BLM stock wells within one mile of the Permit Area 

boundary could be impacted due to the drawdowns associated with groundwater 

withdrawal during Mine Unit Operation and Reclamation. If significant impacts 

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

usefulness of the wells), the following measures would be considered: 

 lowering the pump level in the wells; 

 deepening the wells; and 

 replacing the wells with new wells completed in deeper sands that are not 

impacted by the Project. 

4.7.2 Groundwater Monitoring 

Similar to the discussion of agency-required measures, the discussion of 

groundwater monitoring is separated on the basis of on-site and off-site 

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monitoring because of the different concerns. On-site, the concerns are related to 

ensuring that Mine Unit Operation and Reclamation are conducted as efficiently 

as possible, and emphasize monitoring of water levels and water quality, in 

addition to pattern balancing. The monitoring is also intended to ensure 

excursions do not occur, or if they do occur, they are controlled as quickly as 

possible to prevent movement of lixiviant and production fluid outside of the 

monitor well ring. Off-site, the concern is related to the extent to which on-site 

groundwater extraction, particularly during the first phase of restoration, would 

draw down water levels in off-site wells. 

4.7.2.1 On-Site Groundwater Monitoring 

Permit Area 

Water level measurements would be taken quarterly in the 27 wells that were used 

to establish baseline conditions within the Permit Area as described in Section 

3.6.4.2. Other samples may be collected from these wells, depending on the 

development of mine units near or encompassing the wells. 

Storage Ponds 

To help ensure shallow groundwater is not impacted by the two Storage Ponds, 

which are part of the waste treatment and handling system, the Storage Ponds 

would be designed, inspected and monitored in accordance with NRC Regulatory 

Guide 3.11 (2008a). The Storage Ponds, associated inspection schedule and 

monitoring system, and corrective actions that would be taken in case a leak is 

detected, are briefly described in detail in Sections 3.0 and 5.0 of the NRC 

Technical Report (LCI, 2010). In addition to installation of a leak detection 

system as the Storage Ponds are constructed, four wells would provide additional 

monitoring capability. The monitor wells would be drilled to the first shale below 

the surface. Three of the four wells have already been installed and groundwater 

was not encountered in the wells above the first significant aquitard. The wells 

would be checked prior to operation to determine if groundwater exists and, if it 

does exist, the quality of the groundwater. If groundwater does exist, it would be 

sampled on a quarterly basis for conductance, alkalinity, sodium, and sulfate 

(NRC Technical Report [LCI, 2010]). 

Pipelines and Related Equipment 

Flow through the pipelines would be monitored and would be at a relatively low 

pressure. Sensors wired to automatic alarms and pipeline shutoffs would be 

installed to detect significant changes in flow rates or pressures in the pipelines 

and tanks to help prevent significant releases. All the Plant equipment is specified 

and designed for the life of the Project, and equipment for the mine units is 

similarly designed. Visual inspection of pipelines and related facilities is the 

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daily responsibility of all mine site staff. Particularly, it is the responsibility of 

the mine unit operators to inspect these items on a routine basis. 

Mine Units 

In addition to the baseline monitoring already conducted for the Permit Area, 

extensive groundwater monitoring would be conducted on a mine unit basis prior 

to, during and following production to identify any potential impacts to water 

resources of the area. This monitoring is summarized below and described in 

more detail in Section OP 3.6 of the WDEQ-LQD Permit to Mine (LCI, 2011b) 

and Sections 5.7.8.2 and 6.2 of the NRC Technical Report (LCI, 2010). 

Prior to use of any of the monitoring, production, or injection wells, the 

mechanical integrity of the well would be tested. MITs would also be conducted 

at specified intervals thereafter and after well repairs (Section OP 3.4 of the 

WDEQ-LQD Permit to Mine [LCI, 2011b]). The purpose of this monitoring is to 

ensure that fluids in the well cannot migrate into sands other than the one(s) in 

which the well is completed. 

Mine unit monitoring, prior to production, provided information on aquifer 

characteristics needed to refine anticipated operating parameters, such as pumping 

rates and monitor well spacing, and baseline water quality, needed to establish 

excursion indicators and restoration criteria. The WDEQ-LQD MU1 documents 

(LCI, 2011b) includes the results of the aquifer testing and baseline water quality 

for that mine unit, and similar detail would be provided for the other mine units. 

The mine unit monitoring during Mine Unit Operation has two purposes: to 

ensure the operations are being conducted as efficiently as possible to prevent an 

excursion; and to detect any excursions that might occur. During ISR operations, 

water levels would be routinely measured in the production zone and overlying 

and underlying aquifers. Sudden changes in water levels within the production 

zone may indicate that the mine unit flow system is out of balance. Flow rates 

would be adjusted to correct this situation. Increases in water levels in the 

overlying aquifer or underlying aquifers may be an indication of fluid migration 

from the production zone. Adjustments to well flow rates or complete shut-down 

of individual wells may be required to correct this situation. Increases in water 

levels in the overlying aquifer may also be an indication of casing failure in a 

production, injection or monitor well. Isolation and shut down of individual wells 

can be used to determine the well causing the water level increases. These 

monitoring procedures and the operational procedures to address any concerns 

found during monitoring are described in detail in Attachment OP-2 of the 

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

LCI would monitor for lateral movement of lixiviant using a horizontal excursion 

monitoring system. This system consists of a ring of monitor wells completed in 

the same aquifer and zone as the injection and production wells (Figure 2.1-4). It 

is anticipated that monitor wells would be installed about 500 feet from the mine 

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unit boundary and appropriately spaced (approximately 500 feet apart) to detect 

an excursion in a timely manner based on the hydrologic characteristics of each 

mine unit. Monitor wells would be sampled semi-monthly for approved 

excursion indicators, commonly called Upper Control Limits (UCLs). 

Selection of UCLs is based on background water quality, lixiviant characteristics, 

and parameters that move quickly through the aquifer. For example, chloride is 

often a UCL parameter because it moves quickly, in contrast with uranium which 

generally reacts with the aquifer material and, as a result, moves more slowly in 

the groundwater. WDEQ-LQD Guideline No. 4 (2000a) specifies procedures for 

selecting UCL parameters and calculating the UCL concentrations that would 

indicate an excursion had occurred. If an excursion is detected, specific 

requirements for monitoring and controlling the excursion are included in Section 

OP 3.6.4.3 of the WDEQ-LQD Permit to Mine (LCI, 2011b) per the WDEQ-LQD 

NonCoal Rules, Chapter 11, Sections 12 and 13. 

LCI would also monitor for vertical excursions in the overlying and underlying 

aquifers using shallow and deep monitor wells, respectively. Per existing state 

and federal guidance, these wells would be located within the mine unit boundary 

at a density of about one well per four acres, depending on the hydrologic 

characteristics of each mine unit. Shallow and deep monitor wells would be 

sampled semi-monthly for approved UCLs. Section 5.2 of the WDEQ-LQD MU1 

documents (LCI, 2011b) includes the results of UCL calculations for that mine 

unit, and similar detail would be provided for the other mine units. 

The emphasis of monitoring during groundwater restoration is to ensure the 

groundwater quality is restored to the specified criteria determined from the 

baseline sampling and that the quality remains stable (Section RP 2.4 of the 

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

UIC Class I Wells 

These wells are part of the waste treatment and handling system and would be 

much deeper than any mine unit. Mechanical integrity testing of these wells is 

required prior to use, and periodically thereafter, and monitoring injection rates, 

pressures, and injectate quality is also required, in accordance with the WDEQWQD Permit, which is included in Attachment ADJ-2 of the WDEQ-LQD Permit 

to Mine (LCI, 2011b). These wells are briefly described in Section 2.1.2.4 and 

Sections 3.0 and 5.7 of the NRC Technical Report (LCI, 2010). 

4.7.2.2 Off-Site Groundwater Monitoring 

The four BLM stock wells near the Permit Area (Battle Spring Well No. 4451 and 

Battle Spring Well No. 4777, Boundary Well No. 4775, and the Eagle Nest Draw 

Well) shown on Figure 3.6-15 would be sampled to establish background 

conditions if the owner consents and the pumping systems are in working order. 

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The four wells would also be sampled on a quarterly basis if the owner consents 

and the pumping systems are in working order. At a minimum, the samples 

would be analyzed for U-nat and Ra-226. Water level data would be collected 

before sampling if the wellhead design allows access. LCI would also correspond 

with BLM to ensure that the stock reservoirs and wells are not impacted in a 

manner that restricts their intended use. 

4.7.3 Impact Significance Criteria 

The BLM and WDEQ criteria used to evaluate groundwater impacts include both 

qualitative and quantitative assessment of changes in groundwater quantity and 

quality during the Project. The quantitative assessments include calculation of 

anticipated drawdowns in water levels and comparison of operational and restored 

water quality to baseline conditions. 

The BLM Groundwater Impact Significant Criteria are as follows: 

 The natural flow or level of groundwater to existing local springs, seeps, 

flowing artesian wells, or permitted water supply wells is interrupted or 

reduced to the point beneficial uses cannot be maintained. 

 Groundwater quality in any aquifer is degraded such that it can no longer 

be classified for its current and potential use(s). 

WDEQ-LQD requires an assessment of impacts that may reasonably be expected 

as a result of the mining operation to water resources and water rights, which 

includes assessment of the areal extent of drawdown, usually to the extent of the 

five-foot drawdown contour, potential effects on existing water rights, and water 

quality changes (WDEQ-LQD, 2005a and b). WDEQ-WQD has criteria for 

evaluating potential water uses based on water quality (WDEQ-WQD Rules, 

Chapter 8, Table I). The requirements for restoration of groundwater quality after 

ISR, which apply throughout the mine units, are specified in WDEQ-LQD 

NonCoal Rules (Chapter 11, Section 5) and are based on restoring the quality to 

the uses for which it was suitable prior to mining, as established by WDEQ-WQD 

(Section RP 2.2 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). 

To establish requirements for restoration of groundwater quality after ISR, the 

NRC may allow a somewhat different approach than WDEQ-LQD in that the use 

of Alternate Concentration Limits (ACLs) may be approved. Depending on the 

baseline water quality in the Permit Area, the production zone generally must be 

reclassified and exempted per the water use classifications of WDEQ and the 

aquifer exemption provisions of the EPA UIC regulations. The ACLs, if 

approved by NRC, would apply at the exemption boundary. 

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4.7.4	 Differentiation of Impacts to Groundwater -

Consumption and Quality 

Potential impacts to groundwater could occur during all phases of the Project 

(Construction, Operation, and Reclamation). The impacts are from both 

groundwater consumption and changes to groundwater quality. The impacts 

related to groundwater consumption are summarized in Table 4.7-1 and Section 

4.7.4.1, and the impacts related to groundwater quality are summarized in Table 

4.7-2 and Section 4.7.4.2. 

Detailed discussion of the potential impacts to groundwater is provided in the 

following sections for each phase of the Project (Section 4.7.5 – Construction, 

Section 4.7.6 – Operation, and Section 4.7.7 – Reclamation). For each phase, the 

discussion is organized on the basis of the facility or activity that could cause the 

impact or be impacted. Specifically, the discussion is separated on the basis of 

the overall Permit Area, pipelines, related equipment, the Storage Ponds, the mine 

units, the UIC Class I wells, and off-site wells. Impacts from the No Action 

Alternative and the Other Action Alternatives are evaluated in Section 4.7.8. 

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Table 4.7-2 Summary of Water Quality Impacts 

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4.7.4.1 Groundwater Consumption 

Groundwater extraction is a key component of ISR production and aquifer 

restoration. As discussed in Section 2.1, during production, most of the extracted 

groundwater is re-injected into the mine units. Mine units would be operated with 

a 0.5 to 1.5 percent bleed for two to three and a half years depending on the mine 

unit. The bleed would create an inward hydraulic gradient to the mine unit. This 

bleed rate at a maximum scenario of 1.5 percent would produce a volume of 90 

gpm of liquid waste (47,304,000 gallons per year). This accounts for the majority 

of the groundwater consumptive use during Mine Unit Operation. LCI proposes 

to manage the liquid waste through the UIC Class I well(s). The water balance 

for the life of the Project is summarized in Section 2.1.6.2, including Figures 2.1-

9 through 2.1-14, and discussed in more detail in Section OP 3.6.3.1 (Figures OP5a through 5f) of the WDEQ-LQD Permit to Mine (LCI, 2011b). 

During aquifer restoration, the primary methods include groundwater sweep 

(GWS) and reverse osmosis (RO). Other methods, including groundwater 

transfer, RO with permeate reinjection, or reductant addition may also be used. 

Section 4.7.1.1 of this EIS and Section RP 2.3 of the WDEQ-LQD Permit to 

Mine provides additional detail on these methods, including volume calculations. 

During groundwater sweep, groundwater is initially extracted without re-injection 

to hydraulically capture water impacted by production and to draw ambient, 

baseline-quality water into the mine unit from the surrounding aquifer. During 

this sweep, an inward hydraulic gradient is created causing an influx of baseline 

quality native groundwater into the unit, thereby flushing any residual lixiviant 

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

during mining. This sweep accounts for the largest consumptive use of 

groundwater during the Project. 

Following the sweep, groundwater is extracted and treated using RO. RO is a 

water treatment process that works by forcing a solution from a region of high 

solute concentration through a semipermeable membrane to a region of low solute 

concentration by applying a pressure in excess of the osmotic pressure. This 

treatment is most effective in returning the concentrations of total dissolved solids 

and trace metals and the aquifer pH to baseline values. The bulk of the treated 

water is re-injected into the affected aquifer to improve water quality, but a bleed 

rate is maintained, which would result in continued groundwater consumption, 

although at a much reduced rate compared to sweep. 

4.7.4.2 Groundwater Quality 

LCI has committed to return the groundwater to the pre-operational class-of-use 

in accordance with WDEQ statutes and regulations. Best Practicable Technology 

(BPT), as defined in the Wyoming Statutes, would be used during restoration. 

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The uranium deposits underlying the Permit Area are primarily roll front deposits 

in fluvial sandstones. The uranium was deposited when oxidized groundwater 

containing the uranium entered reducing conditions in the subsurface aquifers. 

ISR operations essentially reverse the natural processes that deposited the 

uranium. During operations, barren lixiviant would enter the formation through 

the injection wells and flow to the production wells. Lixiviant is a liquid medium 

used to selectively extract (or leach) uranium from ore bodies. This liquid 

medium typically contains an oxidant such as oxygen and/or hydrogen peroxide 

mixed with sodium carbonate or carbon dioxide. For the Lost Creek Project, 

carbonate lixiviant would be made from varying concentrations and combinations 

of sodium carbonate, sodium bicarbonate, carbon dioxide, oxygen, and/or 

hydrogen peroxide and antiscalant added to the native groundwater. The 

combined carbonate/bicarbonate concentration in the injected solution typically 

would be maintained at less than five grams per liter (g/L), and the hydrogen 

peroxide and/or oxygen concentration typically would be less than one g/L. 

These limits help reduce the possibility of “gas lock” in the formation, which 

reduces ISR efficiency (LCI, 2011b). Section D5.2.3, OP1.2, and OP3.1 of the 

WDEQ-LQD Permit to Mine provide additional information on the ore deposition 

and geochemistry. 

Injection wells introduce the carbonate lixiviant into the mineralized zone to 

oxidize the reduced uranium and to complex it with bicarbonates. Pumping from 

production wells draws the lixiviant through the mineralized zone, oxidizing 

additional ore between the injection and production wells. In turn, groundwater 

restoration essentially reverses the effects of the oxidation during ISR operations 

and re-establishes the reducing conditions that were present prior to Mine Unit 

Operation. During the groundwater sweep the affected water in the edge patterns 

of the mine unit is also drawn back into more central portions of the pattern area, 

making the later restoration phases more efficient. Groundwater produced during 

the sweep phase would contain uranium and other constituents including total 

dissolved solids (TDS) and trace metals such as arsenic, molybdenum, selenium, 

and/or vanadium mobilized during production. The initial concentrations of the 

constituents would be similar to those during the later stages of production. With 

enough pumping, the constituent concentrations would decline gradually, 

reflecting the influx of baseline quality water. The water produced during 

groundwater sweep is treated through the restoration plant ion exchange circuit to 

capture uranium and then either treated with reverse osmosis or pumped directly 

to disposal (LCI, 2011b). 

4.7.5 Construction 

The Construction phase includes both the Initial Construction of the Plant and 

other life-of-mine facilities and the progressive Mine Unit Development. Initial 

Construction is expected to last for approximately seven months, and activities 

include building access roads, utility corridors, the Plant, the Storage Ponds, 

pipelines, and drilling and installation of the UIC Class I injection wells. Mine 

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unit development has been included in the Construction Phase although it is 

progressive (one mine unit may be in development while another is in operation). 

Section 4.5.2 in the NRC SEIS summarizes the potential impacts to water 

resources. Groundwater is expected to be influenced during the construction 

phase by the installation of wells, roads, and pipelines; and the usage of 

groundwater during construction. Due to the various BMPs in place, no 

significant impacts to the groundwater are expected. Additionally, groundwater 

would only be used for limited purposes, reducing the quantity being drawn out of 

the ground. 

4.7.5.1	 Permit Area, Storage Ponds, Pipelines and Related 

Equipment 

Impacts to groundwater during Construction would primarily be from 

consumptive use of groundwater and changes in water quality. Groundwater 

consumptive use would primarily be for dust control, drilling, and employee use 

(e.g. showers and toilets). Groundwater quality could be impacted from spills of 

solvents, lubricants or other materials, and the introduction of drilling fluids. The 

impacts to groundwater would be direct and on a short-term basis at specific 

locations within the Permit Area, such as the Plant and utility corridors. 

Groundwater for dust control, drilling, aquifer testing, and employee use would be 

pumped from the water supply wells during the Construction phase. Two wells 

would be installed in the FG Horizon, one well in the HJ Horizon, three wells in 

the KM Horizon, and one well in the N Horizon. Groundwater, estimated at a 

maximum of 35 gpm, would be pumped from the seven water supply wells to 

meet the needs of the Project. The wells would be located away from the ore 

body and the water quality would be tested prior to use. 

The FG aquifer occurs at depths ranging from 250 to 275 ft bgs and is 

approximately 100 feet thick. It is hydrologically separated from the DE aquifer 

and the HJ aquifer. The top of the HJ aquifer ranges from approximately 300 to 

450 ft bgs and ranges in thickness from 100 to 160 feet. It is hydrologically 

separated from the FG aquifer by the Lost Creek Shale and from the underlying 

KM aquifer by the Sagebrush Shale. The top of the KM aquifer ranges from 450 

to 600 ft bgs and is about 100 feet thick. It is hydrologically separated from the 

HJ aquifer and the underlying L Horizon. Minor drawdown could occur as the 

groundwater is withdrawn from the water supply wells. However, because of the 

relatively small volume of water withdrawn relative to the water supply available 

in the aquifers, only minor short-term drawdown impacts are expected. 

The volume of water for dust control, drilling and employee use would be limited. 

For the life of the Project, a very conservative calculation of the drawdown from 

pumping of the water supply wells is less than five feet in the FG, KM and N 

Horizons at distances greater than three miles from the center of the Permit Area; 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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therefore, the drawdown would be much less during the seven months of 

Construction. The calculation and associated assumptions, e.g., no recharge and 

continuous pumping for the life of the Project, are discussed in Section OP 3.6.3.4 

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

The potential volume of stored fuels and lubricants in the Permit Area is expected 

to be small and any leaks or spills would be cleaned up immediately to prevent 

soil contamination and infiltration to the groundwater in accordance with the 

SPCC Plan. 

Water for construction of the Storage Ponds (e.g., for compaction and dust 

suppression) would come from the water supply wells. There is a possibility that 

groundwater could be impacted during installation of the monitor wells for the 

Storage Ponds, although the volume of water required for drilling is not expected 

to create any drawdown. Four wells are required by NRC and WDEQ, and three 

of the four have been installed to demonstrate the absence of groundwater above 

the DE Horizon. Groundwater quality could be impacted from spill of fuels or 

lubricants during construction of the Storage Ponds, but any spills would be 

cleaned up immediately to prevent soil contamination and infiltration to the 

groundwater in accordance with the SWPPP. In addition, the Storage Ponds 

would be constructed in accordance with NRC and WSEO standards. 

4.7.5.2 Mine Units 

The schedule for Mine Unit Development is generally three plus years for each 

mine unit. It includes installing monitoring wells, injection wells, and production 

wells, well development, well sampling, aquifer testing, pipeline installation and 

construction of the header houses and installation of mine unit piping. 

Groundwater levels would be affected during the life of each mine unit. The 

primary consumptive impact to groundwater would occur during Mine Unit 

Operation and Reclamation, which are described in more detail below. However, 

during Mine Unit Development, prior to Operation, all of the wells must be 

drilled, developed, tested, and sampled. On an individual well basis, none of 

these development processes require extensive consumption of water, and even in 

aggregate, the influence is negligible compared with Mine Unit Operation and 

Reclamation. However, the processes do represent a definable impact, if 

measurable only during the short-term (e.g., during the multi-day aquifer test of a 

new monitor well ring). 

During Mine Unit Development, groundwater would be recovered from well 

installation activities, including drilling, well development, sample collection and 

aquifer testing. The groundwater is “native” groundwater that has not been 

exposed to any ISR process or chemicals. This “native” groundwater would be 

discharged to the surface under the provisions of a general WYPDES permit or 

reused in the drilling process. The surface discharge permits would mitigate 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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impacts to the Permit Area aquifers by limiting the discharge volume and 

prescribing concentration limits to discharged waters. In addition, Alternate 

Sediment Control Measures (ASCMs) as described in the WDEQ/LQD Guideline 

15 would be used for erosion and sediment control. No impacts to groundwater 

are anticipated due to the relatively small volume of water discharged at any 

given time. 

Drilling fluids would consist of “native” groundwater and may contain bentonite 

based muds, polymers, inert lost circulation material, and minor amounts of soda 

ash. Hazardous chemicals would not be used in the drilling mud. The drilling 

fluids would be contained in drill pits during the drilling; and the drill pits would 

be backfilled with subsoil either after the drilling fluid has evaporated or to 

prevent displacement of the drilling fluid. Because of the relatively small 

quantities of water used for drilling and the nature of the drilling fluid, no impacts 

to groundwater are anticipated. LCI has estimated that 10 drill rigs per week 

would be used during the drilling phase of the project and each rig would use 

approximately 3,400 gallons of water per day. 

Groundwater would be pumped for sample collection and aquifer characterization 

prior to Mine Unit Operation or from portions of the Permit Area not affected by 

ISR operations. This “native” groundwater has not been exposed to any ISR

process or chemicals. During sample collection and aquifer testing, the water 

would be discharged to the surface in accordance with WYPDES permits or 

would be reused in the drilling process. The surface discharge permits would 

mitigate impacts to the Permit Area aquifers by limiting discharge volumes and 

concentration limits and ASCMs would be used for erosion and sediment control. 

It is not anticipated that withdrawal of groundwater from the water supply wells 

would cause significant drawdown based on the duration of the Mine Unit 

Development stage. Because of the relatively small quantities of water 

discharged and the implementation of BMPs (as described in the Operations Plan 

of the WDEQ Permit to Mine), impacts on water quality would be insignificant. 

Non-hazardous drilling fluids, as described above, would be limited and would be 

contained in drill pits to minimize the area of potential soil contamination and to 

enhance evaporation. Fluid leakage from drill pits or spills of drilling mud during 

well installation activities should not have any impacts on groundwater, due on 

the depth of the groundwater and the low-permeability mudstone/shale overlying 

the DE aquifer. During drilling the procedures detailed in the Operations Plan of 

the WDEQ Permit to Mine (LCI 2011b) would be implemented to prevent, 

identify, and correct any impacts to groundwater in the event of spills. In the 

unlikely event that the drilling fluid does migrate down to the groundwater in the 

DE Horizon there could be a minor long-term impact to the groundwater quality 

without remediation; however, any impacts to groundwater would quickly be 

mitigated since regulations require immediate and complete restoration. 

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For wells drilled in active mine units, the groundwater generated during well 

development and aquifer testing would be treated as 11(e)(2) byproduct material. 

This affected groundwater would be disposed of on-site through a system of 

Storage Ponds and UIC Class I wells. Procedures for the Prevention and 

Remediation of Accidental Releases are discussed in the Operations Plan of the 

WDEQ Permit to Mine (LCI, 2011b). Because of the controlled on-site disposal 

procedures, no impacts to groundwater from the liquid waste are anticipated. If a 

release does occur and if the 11(e)(2) byproduct material does migrate to the 

groundwater in the DE Horizon the impact would be high and long-term. 

4.7.5.3 UIC Class I Wells 

Up to five UIC Class I wells would be installed in the Permit Area. The wells 

would be completed at depths ranging from approximately 6,170 to 8,100 ft bgs. 

As discussed in Section 2.1.1, LCI obtained Permit No. 09-586 from the WDEQWQD to dispose process waste water in the Fort Union Formation, which is 

estimated to be approximately 4,800 thick in the Permit Area. A 300-foot thick 

low-permeability shale sequence at the base of the Wasatch/Battle Springs 

Formations overlies the Fort Union Formation and would act as the confinement 

layer. The confining layer below the injection zone is the Cretaceous-age 1,900-

foot thick Upper Lance Formation, which consist of shales, siltstones, and lesser 

sandstone. Additional information regarding the 300-foot shale confining layer is 

in the Application for an Underground Injection Control Permit, Class I prepared 

for LCI by Petrotek, 2010. The document is in the Adjudication File for the 

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

Impacts to deeper groundwater could occur from the introduction of drilling mud 

and fluids during drilling and installation of the deep wells. However, the impacts 

would be minimal because the drilling muds are designed to seal the permeable 

zones by depositing the mud filter cake on the wellbore wall. 

Drilling fluids would be contained in mud pits to minimize the area of potential 

soil contamination and to enhance evaporation. Leakage from mud pits or spills 

or leaks during Construction should not have any detectable impacts on the 

groundwater, based on the depth of the groundwater below the surface, the clay 

content in the mud pits, and the low-permeability shale overlying the aquifers. 

Drill stem tests would be conducted to ensure the wells have the required 

injection capacity; however, water consumption during such testing is minimal 

because of the emphasis on pressure measurement rather than water pumping. As 

noted in previous sections, the deep well in the southwest corner of the Permit 

Area was installed in 2008 to confirm the viability of using the deep wells for 

disposal. The groundwater recovered from well development, sample collection 

and drill-stem testing would be evaporated in the mud pit or disposed in one of 

the on-site UIC disposal wells or disposed of in an off-site disposal well. Other 

disposal options that are compliant with all of the applicable regulations may be 

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used for the disposal of the groundwater associated with the drilling and 

installation of other on-site UIC disposal wells. No impacts to groundwater 

quality are anticipated due to the relatively small volume of water that would be 

discharged. 

4.7.6 Operation 

The Operation phase for the Project is scheduled for seven plus years. Potential 

environmental impacts to groundwater during the Operation phase include 

changes to groundwater levels and quality due to the ISR process and 

consumptive use of groundwater. The ISR process uses a carbonate lixiviant that 

is pumped through buried pipelines to injection wells in the mine units. The 

lixiviant is circulated through the ore zone from the injection wells to the 

production wells, where it is then pumped from the mine units through buried 

pipelines to the ion exchange circuit in the Plant. Waste water would be 

temporarily stored in the Storage Ponds and then pumped into the deep disposal 

wells. Leaks of lixiviant from the wells, pipelines and header houses or waste 

water leaks from the Storage Ponds could impact groundwater resources in the 

Permit Area. However near-surface aquifers are not present within the Permit 

Area; therefore, the risk of impacting the deeper groundwater resources is small. 

The potential impacts are discussed below on the basis of Consumptive (Section 

4.7.4.1) and Water Quality (Section 4.7.4.2). 

Section 4.5.2 in the NRC SEIS summarizes the potential impacts to water 

resources. Groundwater is expected to be influenced during the operation phase 

by the potential for leaks and spills of chemicals and pumping for use on for the 

project. Due to the protective measures and chemical clean-up in place, only 

minor long-term impacts to the groundwater are expected. Also, groundwater 

usage is limited to only a few purposes, limiting the amount of water that would 

be pumped from the ground. 

4.7.6.1 Groundwater Consumption during Operation 

Permit Area 

Groundwater for dust control, drilling, cement mixing and employee use would 

continue to be pumped from on-site water supply wells, and as described under 

Construction, a very conservative calculation of the drawdown from pumping of 

the water supply wells is less than five feet in the FG, KM and N Horizons at 

distances greater than three miles from the center of the Permit Area. It is not 

anticipated that withdrawal from the water supply wells would cause significant 

drawdown in the HJ Horizon based on the intervening shale(s) between the HJ 

Horizon and the supply well completion intervals and the low projected pumping 

rates. It is possible that pumping from the UFG could result in drawdown within 

the LFG, which is the overlying aquifer to the production zone. If drawdown 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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becomes apparent within the LFG monitor wells inside a mine unit, the shallow 

water supply well (e.g., LC1W) would be temporarily shut-in and the water level 

response in the LFG monitor wells would be observed. If the water levels recover 

within the LFG wells once the pumping in the UFG is stopped, then the water 

supply well would be identified as the cause of water level decreases. If water 

level recovery does not occur in the LFG, then LCI would act on the assumption 

that operation of the mine unit is causing the drawdown and would proceed 

accordingly with corrective action, if necessary. Similarly, pumping from a UKM 

completed well (e.g., LC28M) could result in unanticipated drawdown in the KM 

Horizon, which would be addressed in a comparable manner. 

Storage Ponds, Pipelines and Related Equipment 

None of these facilities would impact the consumptive use of groundwater. As 

discussed in Section 4.7.4.2, the potential exists for leakage to create an area of 

perched groundwater, but this would require corrective action. 

Mine Units 

During Operation the water level changes, including both drawdown and 

mounding from production and injection, respectively, would be evaluated to 

minimize interference among the mine units and to determine cumulative impacts. 

Overall, the bleed rate of 0.5 percent to 1.5 percent, which has been historically 

applied at numerous ISR facilities, would create a cone of depression around each 

pattern area. The bleed water would be disposed of in the UIC Class I Injection 

Wells. The vast majority (e.g., on the order of 99 percent) of groundwater used 

during Mine Unit Operation would be treated and re-injected. The average rate of 

groundwater withdrawal (consumptive use) during production is around 70 gpm. 

The highest rate of groundwater withdrawal during production, groundwater 

sweep, and RO treatment would be on the order of 115 gpm. The water balance 

for the life of the Project is summarized in Section 2.1.6.2, including Figures 

2.1-9 through 2.1-14, and discussed in more detail in Section OP 3.6.3.1 (Figures 

OP-5a through 5f) of the WDEQ-LQD Permit to Mine (LCI, 2011b). 

Results of the hydrologic investigations to date indicate that the HJ aquifer is 

laterally extensive and hydraulically connected, except where separated by the 

Fault (Section 3.6). Furthermore, the HJ aquifer is hydraulically separated from 

the overlying and underlying aquifers by laterally continuous confining units. 

Groundwater consumption during Mine Unit Operation would generally be 

limited to the HJ aquifer. 

Drawdown during Operation would be greatest in the immediate vicinity of the 

mine units. A numerical model was used to assess drawdown impacts from 

Project. The model was developed using site-specific geologic and hydrologic 

data collected from site characterization activities. The model development, 

calibration and simulations are described in the report, “Numerical Modeling of

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Hydrologic Conditions at the Lost Creek Uranium In-Situ Recovery Project, 

Wyoming,” in Addendum 5-1 of the WDEQ-LQD MU1 document (LCI, 2011b). 

Simulations were run representing the full production-restoration sequence for 

MU1. The simulation included a maximum production rate of 5,838 gpm (with a 

net bleed of 38 gpm or 0.65 percent) for a period of 26 months (791 days), 

groundwater sweep at 30 gpm for 12 months (365 days), and treatment with RO 

at 541 gpm for 18 months (548 days). The total simulation period was 56 months 

(4.75 years). During RO, the simulated consumptive use (reject brine) was 67.6 

gpm. Simulated drawdown during the maximum production rate is shown on 

Figure 4.7-1. Drawdown during the RO phase is shown on Figure 4.7-2. The 

five-foot drawdown contour extends a maximum of 3.3 miles (17,250 feet) 

beyond the Permit Area boundary. The maximum drawdown outside the Permit 

Area boundary is slightly greater than 25 feet. This occurs where MU1 is closest 

to the Permit Area boundary. Although this simulation only represents MU1 

production and restoration, the production and RO rates are maximized. During a 

portion of the Project, full production and restoration could occur simultaneously; 

thus, the cumulative effect is represented by combining the predictions 

represented on the figures and accounting for some shift in mine unit location. 

Simulated recovery of water levels in the HJ Horizon aquifer after termination of 

ISR operations in MU1 is illustrated by placing observation points on the 

northwest, southwest, northeast and south-central edges of the Permit Area. 

Figure 4.7-3 shows the location of the simulation monitoring points. Figure 

4.7-4 illustrates the simulated drawdown that occurs during ISR operations at 

MU1 and the recovery following termination of operations. The water levels are 

projected to recharge within ten to 15 years, once groundwater extraction ceases. 

The model development, calibration and simulations are described in the report 

“Numerical Modeling of Hydrologic Conditions at the Lost Creek Uranium InSitu Recovery Project, Wyoming”, which is included as Attachment MU1 5-1 in 

the WDEQ-LQD MU1 documents (LCI, 2011b). 

UIC Class I Wells 

The UIC Class I injection wells would be competed in the Fort Union Formation. 

Process waste water would be injected at an average rate of 70 gpm. The 

proposed locations of the five UIC Class I wells are widely scattered to 

accommodate regulatory requirements and meet the necessary injection criteria 

(Figure 1.2-2). These wells would be used for injection, not pumping; therefore, 

no consumptive use would occur. With respect to injection capacity, testing 

results from the first well installed in the southwest corner of the Permit Area 

indicate sufficient capacity for the planned disposal quantities. In addition, the 

TDS concentration in the formation water was in excess of 10,000 mg/L and the 

concentration of other organic and inorganic constituents exceeded groundwater 

quality standards (Section 3.6.4). Although LCI has permitted five wells, 

installation of only two to three wells is planned initially, with installation of the 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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fourth and fifth wells based on the need for redundant capacity if another well 

must be taken out of service. 

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East Eagle Nest Draw 

Boundary Well No. 4775 

Battle Spring Draw Well No. 4451 

Battle Spring Well No. 4777 
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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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Off-Site 

BLM has four wells located outside of the Permit Area (Figure 3.6-15). The 

completion depths of two of these wells are shallower than the HJ Horizon; the 

completion depth of another is substantially greater than the HJ Horizon (although 

the screened interval is not known). The completion depth of the fourth well may 

coincide with the LFG Sand; as such, potential drawdown may affect this well. 

4.7.6.2 Groundwater Quality during Operation 

Permit Area 

No groundwater quality impacts are anticipated from pumping of the water supply 

wells. Any water level declines in these wells are not expected to impact the 

water quality because of the relative similarity in the water quality at these depths. 

Storage Ponds, Pipelines and Related Equipment 

Groundwater quality could potentially be impacted during the Operation phase 

due to an accident such as Storage Pond leakage/failure or an uncontrolled release 

of liquids due to a mine unit accident. Because of the depth to water in the DE 

Horizon and the presence of shale layers between DE Sands and the surface, 

direct leakage to the groundwater is considered unlikely and would be the result 

of a slow leak or catastrophic failure. However, it could be possible for a leak to 

create an area of perched groundwater. To minimize the chance of a leak, the 

Storage Ponds would be designed and built to NRC standards using double liners 

with a leak detection system between the two liners. The liner material would 

consist of impermeable polypropylene geomembrane and each liner would be 41 

millimeters (approximately 1,600 mils) thick. The ponds would be inspected on a 

regular basis. If a major release does occur and if the 11(e)(2) byproduct material 

does migrate to the groundwater in the DE Horizon the impact would be high and 

long-term. 

Mine Units 

ISR from a uranium deposit is accomplished by reversing the natural processes 

that deposited the uranium, i.e., ISR reoxidizes the ore zone to mobilize the 

uranium from the reduced conditions in the ore zone. A small portion of radium 

would be mobilized with the uranium, and depending on the conditions within a 

given sand other metals such as arsenic, molybdenum, selenium, and/or vanadium 

may also be mobilized during ISR. 

The native formation waters in the ore zones of the HJ Horizon are not suitable 

for human consumption because of naturally high levels of dissolved radioactive 

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materials, including uranium and Ra-226 (Section 3.6.4). The ISR process affects 

the pattern area within the mine unit, which was exempted per the water use 

classifications of the WDEQ and the aquifer exemption provisions of the EPA 

UIC regulations. The area so designated was limited both laterally and vertically. 

During Mine Unit Operation, injection of the lixiviant into the pattern area results 

in a temporary degradation of water quality in that area compared to preproduction conditions. However, proper balancing of pumping and injection rates 

and pressures, as described in Section OP 3.6 and Attachment OP-2 of the 

WDEQ-LQD Permit to Mine (LCI, 2011b), restricts these water quality changes 

to the pattern area and improves mining efficiency. Subsequent restoration 

activities, described in Section RP 2.3 of the WDEQ-LQD Permit to Mine (LCI, 

2011b), are also designed to affect the pattern area. 

The target horizon for the Project is the HJ Horizon. Hence, the ISR operations 

would impact water quality only in the HJ Horizon provided excursions do not 

occur. Inadvertent movement of the affected water out of the pattern area is 

termed an excursion. Excursions represent an impact on the groundwater outside 

of the pattern area, and possibly the mine unit (Figure 2.1-5). Excursions can 

result from an improper balance between injection and recovery rates, undetected 

high permeability strata or geologic faults, improperly abandoned exploration drill 

holes, discontinuity of the confining units that could allow movement of the 

lixiviant out of the ore zone, poor well integrity, or hydrofracturing of the ore 

zone or surrounding units if the injection wells were operated above fracture 

pressure. Protective measures are required to avert these scenarios (Section 

4.7.1), and systematic monitoring is designed to detect them as early as possible 

(Section 4.7.2). Mitigation measures and time frames for implementing those 

measures are required if an excursion occurs (Section 4.7.1.1) 

A problem due to poor well construction or well damage could result in migration 

of fluids between aquifers. Because of the depth to water in the DE Horizon and 

the presence of shale layers between DE Sands and the surface, a shallow leak 

from a well could create an area of perched groundwater. 

UIC Class I Wells 

As with any well, a problem due to poor well construction or well damage could 

result in migration of fluids between aquifers. However, the construction and 

monitoring requirements described in Sections 4.7.1 and 4.7.2 are designed to 

prevent, detect, and correct this problem. Another potential concern would be the 

loss of injection capacity due to precipitates forming in the injection zone. 

Comparison of the anticipated composition of the waste stream and the existing 

water quality in the injection zone does not indicate chemical incompatibility 

between the fluids, as shown in Table 4.7-3. Because of the elevated 

concentrations of Total Dissolved Solids in the target formation fluids, an aquifer 

exemption for the target formation was not a requirement. 

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Table 4.7-3 Comparison of Water Quality in the Injection Stream and the Receiv

Formation 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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Off-Site 

No water quality impacts to the BLM wells are expected because the completion 

intervals coincide only partially, if at all, with the HJ Horizon. In addition, 

because of the distance of these wells from the pattern areas and excursion 

control, any water level declines in the BLM wells are not expected to impact the 

water quality because of the relative similarity in the water quality at these depths. 

4.7.7 Reclamation 

Reclamation includes progressive Mine Unit Restoration and Final Reclamation. 

Groundwater impacts are related to water quantity, through consumptive use, and 

to water quality through waste management practices including discharge to the 

storage ponds and deep wells. The potential impacts are discussed on the basis of 

Consumption (Section 4.7.7.1) and Water Quality (Section 4.7.7.2). 

Section 4.5.2 in the NRC SEIS (NRC, 2011a) also summarizes the potential 

impacts to water resources during reclamation. Groundwater is expected to be 

influenced during the reclamation phase by the decommissioning of the wells, 

potential leaks and spills, and use of the groundwater. Due to the various BMPs 

in place, no significant impacts from leaks and spills are expected to the 

groundwater are expected. Well abandonment is conducted to return the 

hydrological conditions to their previous state and use of the groundwater is 

limited to certain purposes. As such, while the groundwater may be affected in 

the short-term, in the long-term it would be returned to its previous state. 

4.7.7.1 Groundwater Consumption during Reclamation 

Permit Area 

Groundwater for dust control, well plugging and abandonment, cement mixing 

and employee use would continue to be pumped from on-site water supply wells 

during Mine Unit Reclamation. The drawdown from pumping of the water 

supply wells would be less than five feet in the FG, KM and N Horizons at 

distances greater than three miles from the center of the Permit Area. It is not 

anticipated that withdrawal from the water supply wells would cause significant 

drawdown in the HJ Horizon based on the intervening shale(s) between the HJ 

Horizon and the supply well completion intervals and the low projected pumping 

rates. It is possible that pumping from the UFG could result in drawdown within 

the LFG, which is the overlying aquifer to the production zone. If drawdown 

becomes apparent within the LFG monitor wells inside a mine unit, the shallow 

water supply well (e.g., LC1W) would be temporarily shut-in and the water level 

response in the LFG monitor wells would be observed. If the water levels recover 

within the LFG wells once the pumping in the UFG is stopped, then the water 

supply well would be identified as the cause of water level decreases. If water 

level recovery does not occur in the LFG, then LCI would act on the assumption 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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that operation of the mine unit is causing the drawdown and would proceed 

accordingly with corrective action, if necessary. Similarly, pumping from a UKM 

completed well (e.g., LC28M) could result in unanticipated drawdown in the KM 

Horizon, which would be addressed in a comparable manner. 

The potential impacts to groundwater during Final Reclamation would be similar 

to those during Construction. An additional water use during Final Reclamation 

would be for decommissioning the Plant. LCI estimates that approximately 

34,000 gallons of water would be required to decontaminate and decommission 

the Plant and associated equipment. Using a 100 percent contingency factor, the 

total volume of water required for decontaminating and decommissioning is 

around 68,000 gallons of groundwater. The waste water generated during the 

decontaminating and decommissioning would be disposed in the UIC Class I 

wells in accordance with NRC requirements. 

Storage Ponds, Pipelines and Related Equipment 

None of these facilities would impact the consumptive use of groundwater during 

Mine Unit Reclamation or Final Reclamation. 

Mine Units 

Drawdown during mine unit reclamation would be greatest in the immediate 

vicinity of the mine unit in restoration and greatest during groundwater sweep 

(GWS), when water is pumped from the mine unit without offsetting with water 

injection. As discussed in Section 4.7.4.1, a numerical model was used to assess 

drawdown impacts from Project. The model was developed using site-specific 

geologic and hydrologic data collected from site characterization activities. 

Simulated recovery of water levels in the HJ Horizon aquifer after termination of 

ISR operations in MU1 is illustrated by placing observation points on the 

northwest, southwest, northeast and south-central edges of the Permit Area. 

Figure 4.7-3 shows the location of the simulation monitoring points. Figure 

4.7-4 illustrates the simulated drawdown that occurs during ISR operations at 

MU1 and the recovery following termination of operations. The water levels are 

projected to recharge within ten to 15 years, once groundwater extraction ceases. 

During reverse osmosis (RO), the simulated consumptive use (reject brine) was 

67.6 gpm. Drawdown during the RO phase is shown on Figure 4.7-2. The fivefoot drawdown contour extends a maximum of 3.3 miles (17,250 feet) beyond the 

Permit Area boundary. The maximum drawdown outside the Permit Area 

boundary is slightly greater than 25 feet. This occurs where MU1 is closest to the 

Permit Area boundary. Although this simulation only represents MU1 production 

and restoration, the production and RO rates are maximized. During a portion of 

the Project, full production and restoration could occur simultaneously; thus, the 

cumulative effect is represented by combining the predictions represented on the 

figures and accounting for some shift in mine unit location. 

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UIC Class I Wells 

These wells would be used for injection, not pumping; therefore, no consumptive 

use would occur during reclamation. During Final Reclamation, the UIC Class I 

wells would be plugged and abandoned in accordance with the WDEQ-LQD 

Permit (LCI, 2011b). 

Off-Site 

The locations of the four BLM wells located outside of the Permit Area are shown 

on Figures 4.7-1 and 4.7-2. As noted previously, the completion depths of two of 

these wells are shallower than the HJ Horizon; the completion depth of another is 

substantially greater than the HJ Horizon (although the screened interval is not 

known). The completion depth of the fourth well may coincide with the LFG 

Sand; as such, potential drawdown may affect this well. Even if the completion 

intervals of these wells coincided with the HJ Horizon, the drawdown would not 

exceed 15 feet, based on the simulation illustrated on Figure 4.7-2. 

4.7.7.2 Groundwater Quality during Reclamation 

Permit Area 

No groundwater quality impacts are anticipated from the pumping of the water 

supply wells. Any water level declines in these wells are not expected to impact 

the water quality because of the relative similarity in the water quality at these 

depths. 

Storage Ponds, Pipelines and Related Equipment 

Groundwater quality could potentially be impacted during Mine Unit Reclamation 

due to an accident such as Storage Pond leakage or an uncontrolled release of 

liquids due to a mine unit accident. Because of the depth to water in the DE 

Horizon and the presence of shale layers between DE Sands and the surface, 

direct leakage to the groundwater is considered unlikely and would be the result 

of a slow leak or catastrophic failure. However, it could be possible for a leak to 

create an area of perched groundwater. The Storage Ponds would be designed and 

built to NRC standards using impermeable synthetic liners with a leak detection 

system, and all ponds would be inspected on a regular basis. If a major release 

were to occur and if the 11(e)(2) byproduct material migrated to the groundwater 

in the DE Horizon, the impact could be high and long-term without remediation; 

however, any impacts to groundwater would quickly be mitigated since 

regulations require immediate and complete restoration. 

Groundwater quality could potentially be impacted during Final Reclamation due 

to an accident, such as or an uncontrolled release of liquids when the ponds are 

being emptied. 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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Mine Units 

Groundwater restoration after ISR returns the ore zone to reducing conditions, 

reprecipitating any residual uranium mobilized during ISR. TDS and other trace 

metals such as arsenic, molybdenum, selenium, and/or vanadium which may have 

also been mobilized during Operation are also reprecipitated. 

The native formation waters in the ore zones of the HJ Horizon are not suitable 

for human consumption because of naturally high levels of dissolved radioactive 

materials, including uranium and Ra-226 (Section 3.6.4). The ISR process affects 

the pattern area, which was exempted per the water use classifications of the 

WDEQ and the aquifer exemption provisions of the EPA UIC regulations. The 

area so designated was limited both laterally and vertically. Ideally, Mine Unit 

Restoration activities affect only the pattern area. An excursion has been known 

to occur during restoration in rare circumstances, e.g., due to immediate proximity 

to an underground uranium mine, but monitoring is required until restoration is 

deemed complete, and such conditions do not exist at the Lost Creek Permit Area. 

A problem due to poor well construction or well damage could result in migration 

of fluids between aquifers. However, the requirements for monitoring, including 

MITs, continue during mine unit restoration. 

After Mine Unit Restoration is completed and approved by WDEQ-LQD and 

NRC, the wells would be abandoned in accordance with established protocols 

(Section RP 3.1 of the WDEQ-LQD Permit [LCI, 2011b]). No impact from the 

abandonment of the wells is anticipated. 

UIC Class I Wells 

As with any well, a problem due to poor well construction or well damage could 

result in migration of restoration or abandonment fluids between aquifers. 

Another potential concern would be the loss of injection capacity during 

restoration due to precipitates forming in the injection zone. Comparison of the 

anticipated composition of the waste stream and the existing water quality in the 

injection zone does not indicate chemical incompatibility between the fluids, as 

shown in Table 4.7-3, taken from Attachment J of the WDEQ-WQD Permit, 

which is included in Attachment ADJ-2 of the WDEQ-LQD Permit to Mine (LCI, 

2011b). Similarly, the abandonment fluids, which are primarily cement, must 

also be suitable for the subsurface conditions. 

During Final Reclamation, the UIC Class I wells would be plugged and 

abandoned in accordance with the WDEQ-LQD Permit. No impact from the 

abandonment of the wells is anticipated. 

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Off-Site 

No water quality impacts to the BLM wells are expected because the completion 

intervals coincide only partially, if at all, with the HJ Horizon. In addition, 

because of the distance of these wells from the pattern areas and excursion 

control, any water level declines in the BLM wells are not expected to impact the 

water quality because of the relative similarity in the water quality at these depths. 

4.7.8 Groundwater Impacts from Other Alternatives 

4.7.8.1 No Action Alternative 

Under the No Action Alternative, the Project would not be constructed. Existing 

wells drilled for the Project would be plugged in accordance with WDEQ 

regulations. There would be no Project-related impacts to groundwater. 

4.7.8.2 Not Fencing the Pattern Areas 

Considering operational health and safety, the Proposed Action involves fencing 

the pattern areas within the operational mine unit(s) to reduce the possibility of 

damage to the wellheads and other surface facilities by livestock and wild horses. 

Although any damage by livestock and wild horses would likely be restricted to 

surface damage, it is possible that a well could be damaged to such an extent that 

a subsurface leak could occur. However, if a well is damaged to such an extent, 

repair and integrity testing is required before it could be put back into use. In 

addition, an assessment of impacts to soil or water due to leakage from the 

damaged well would be required. 

4.7.8.3 Drying Yellowcake On-Site 

This alternative would have no impact on groundwater. The dryer would be 

within the Plant, so the measures taken to prevent impacts to groundwater from 

the Plant operation, 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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4.8 Vegetation 

4.8.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Sections OP 2.7 and RP 4.5 of the WDEQ-LQD Permit to Mine (LCI, 2011b) and 

Sections 2.1.1.1.2.1, 2.1.1.1.5.5, and 6.2.3 of the NRC SEIS (NRC, 2011a). 

Minimization of vegetation removal, reseeding, and traffic and weed control are 

part of the Proposed Action. Vegetation removal would be minimized whenever 

possible to protect topsoil, preserve wildlife habitat, and improve revegetation 

success. The acreages of the two vegetation communities identified on-site 

(Upland and Lowland Big Sagebrush Shrublands), and the acreages of 

disturbance in those communities are listed in Table 4.5-1. The disturbance 

acreages do not differentiate between areas where topsoil and vegetation are 

removed, i.e., where both the plant and roots are removed, and areas where the 

vegetation is crushed but the roots remain in place. In most of the pattern areas, 

the roots would remain in place, which should help reduce erosion and leave 

organic material in place, and, for shrubs, may provide for more rapid 

reestablishment than just from seed. 

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 

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

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

grass or millet. The permanent seed mix, 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), is shown in Table 4.8-1. 

During the Operation phase, mine units and supporting facilities would be 

accessed using a defined road network. Employees would be trained to minimize 

the impact to vegetation by staying on defined roadways and reducing the amount 

of vehicle traffic to the extent possible. Drilling and construction activities would 

be limited or halted when field conditions are muddy in order to minimize 

damage to vegetation. Alternatively, activities may be shifted to areas where they 

would not impact vegetation. Weed prevention measures following BLM 

guidelines and recommendations would be implemented (BLM, 1996b and 

2004b). 

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Table 4.8-1 Permanent Seed Mix 

1 Application Common Name Scientific Name (pounds per acre) 

Thickspike wheatgrass Agropyron dasystacum 4.0 

Slender wheatgrass Agropyron trachycaulum 2.5 

Western wheatgrass Agropyron smithii 2.0 

Indian ricegrass Achnatherum hymenoides 2.0 

Great Basin wildrye Leymus cinereus 2.0 

Winterfat Ceratoides lanata 1.5 

Sandberg bluegrass Poa secunda 1.5 

2 Big Sagebrush Artemesia tridentata 1.0 

TOTAL 16.5 1 Alternative selections if one or two of primary selections (other than Big Sagebrush) are 

not available: Needle-and-thread (Stipa comata); and Bottlebrush squirreltail ( Elymus 

elymoides) 2 Sage seed would not be mixed with the other seeds but would be broadcast separately 

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4.8.2 Vegetation Monitoring 

Monitoring of vegetation impacts would occur throughout the life of the Project to 

ensure protective measures are working as planned, and vegetation would be 

monitored during Reclamation to ensure reestablishment to required standards. 

4.8.2.1 During Construction, Operation, and Final Reclamation 

LCI personnel would inspect active work areas to ensure employees are 

minimizing impacts to vegetation. Any problems noted during inspections would 

be brought to the supervisor’s attention for correction. Activities throughout the 

Permit Area would also be periodically checked to ensure no unanticipated 

impacts are found. It should be noted that a detailed estimate of the topsoil and 

vegetation disturbance acreage, such as Table 4.5-1 has not been previously 

required for an ISR operation in Wyoming. Therefore, part of the periodic checks 

would be to ensure the approach used to develop this estimate is effective and 

efficient. 

4.8.2.2 Monitoring Revegetation Success 

Both interim and final revegetation efforts would be evaluated. Interim 

revegetation efforts, such as reseeding of a mine unit pattern area after 

construction, would be checked regularly for effectiveness e.g., reducing the 

potential for erosion and controlling weeds. (Interim revegetation is discussed 

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under Drilling and under Surface Facilities in Mine Unit Development in Section 

2.1.3.) 

Revegetation after Final Reclamation would be monitored annually for plant 

germination and growth, weeds, and overall progress toward meeting the 

reclamation success criteria. The monitoring results would be submitted to BLM 

and WDEQ-LQD as part of the Annual Report. If reclamation progress was 

deemed insufficient, then a program to address the concerns (e.g., additional weed 

control or reseeding of poorly germinated area) would be developed in 

conjunction with BLM and WDEQ-LQD. Revegetation after Final Reclamation 

would be deemed complete no earlier than the fifth full growing season after 

seeding and when: 

 the revegetation is self-renewing under the site conditions; 

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

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

total vegetation cover of perennial species (excluding noxious weed 

species) of the undisturbed portions of the Permit Area; 

 the species diversity and composition are suitable for the post-operational 

land use; and 

 the total vegetation cover and species diversity and composition are 

quantitatively assessed in accordance with procedures approved by BLM 

and WDEQ-LQD. 

Because many of the reclaimed areas are relatively small in comparison with the 

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

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

at least six months prior to evaluation of revegetation success for bond release 

(The reclamation bond is discussed under Financial Assurance in Section 2.1.5). 

In addition, LCI would describe the quantitative methods to be used for 

comparing the total vegetation cover in the reclaimed and undisturbed areas and 

for evaluating species diversity and composition. These methods, as well as the 

size and location of the comparison area, would be submitted to BLM and 

WDEQ-LQD for review and approval at least six months prior to the fifth full 

growing season. The sampling results from the evaluation of the reclamation 

success would be reviewed and approved by BLM and WDEQ-LQD prior to 

approval of bond release for surface reclamation. 

4.8.3 Impact Significance Criteria 

Revegetation success after short-term disturbances, e.g., pipeline installation, 

would be evaluated to determine effectiveness in stabilizing topsoil and 

minimizing erosion. Revegetation success after Final Reclamation would be 

evaluated in accordance with BLM and WDEQ-LQD criteria discussed in Section 

2.1.5.2 and 4.8.2. These criteria are in accordance with the Rawlins RMP 

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Management Goals for Vegetation, which are to manage vegetation such that the 

region maintains a diverse and healthy community of plants that continue to 

support and promote ecosystem functions. Additionally, the control of weeds or 

invasive plants would support these management goals. 

4.8.4 Vegetation Impacts from the Proposed Action 

During the life of the Project, a total of approximately 345 acres of the land 

surface and associated vegetation could potentially be disturbed, which is about 

eight percent of the 4,254-acre Permit Area. The disturbance is progressive, i.e., 

it does not all occur during Initial Construction. The disturbance associated with 

each of the Project facilities is listed in Table 4.5-1, and is differentiated by 

vegetation type. Most of the disturbance follows the ore trend, which extends 

east-west through the Permit Area (Figure 2.1-1), and is in the West Battle 

Springs Draw drainage (Figure 3.5-1), which drains most of the Permit Area. 

The disturbance is not concentrated in any one of the three grazing allotments 

(Figure 3.1-2). The acreage that would be disturbed in each vegetation 

community has been estimated, and the actual disturbance would be evaluated 

against that estimate to ensure it is not substantially exceeded. 

Some of the surface disturbance would be long-term, where topsoil and vegetation 

would be removed for the life of the Project, e.g., under the Plant. These areas 

would only be reseeded during Final Reclamation, after the facilities are removed 

and topsoil replaced. Other surface disturbance is considered short-term, e.g., 

pipeline installation, where vegetation and topsoil would be removed, but topsoil 

would be replaced shortly after the disturbance. These areas would be reseeded 

after topsoil replacement to reestablish vegetation for erosion and weed control 

(Section 4.8.1). However, in the following estimates of the affected acres of 

vegetation, all of the disturbance is assumed to be long-term, i.e., no ‘credit’ is 

taken in the acreage estimates for interim reseeding with either the temporary or 

permanent seed mix. This was done because the success of vegetation 

reestablishment, after reclamation is completed in any area, cannot be evaluated 

in accordance with WDEQ-LQD criteria before the fifth full growing season after 

seeding. 

Other vegetation disturbance is due to crushing of the plants by equipment, e.g., 

as drill rigs drive through the pattern areas. Although the roots may remain intact 

in these areas, making vegetation regrowth easier, these areas are included in the 

disturbance estimates. 

Vegetation in the Permit Area could also be impacted by changes in the 

proportions of the species present. Of particular concern is the introduction of 

weeds. Based on the use of effective protection measures (Section 4.8.1), no 

specific acreage estimate was assigned to this impact. The effectiveness of 

reseeding, with either the temporary or permanent seed mix (Section 4.8.1), could 

be impacted by grazing or drought. 

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Spills of fuels, lubricants and other chemicals used during Construction could also 

have an impact on vegetation, if not remediated quickly. Because these impacts 

would be tied to the impacts on soil and because soil conditions would affect the 

ability for vegetation to reestablish itself after such an impact, the discussion of 

these impacts and associated monitoring and mitigation are discussed under Soil 

Impacts (Section 4.5). 

4.8.4.1 Construction 

The Construction phase includes Initial Construction and the progressive Mine 

Unit Development. Initial Construction would require about seven months. Most 

of the disturbance during Initial Construction would be long-term, i.e., lasting for 

the duration of the Project, because it would include vegetation removal from the 

areas on which Project facilities would be built. For the purpose of determining 

the acres of vegetation disturbance during Initial Construction, the ‘life-ofProject’ facilities are listed below and in Table 4.5-1: 

 the Plant and related facilities (e.g., the Storage Ponds); 

 staging areas (even though two of them may not be needed); 

 deep wells and associated pipelines (The deep well in the southwest corner 

of the Permit Area was installed in 2008 to obtain the necessary 

subsurface information on the feasibility of this disposal option. The 

disturbance associated with that well is still included in this estimate. Not 

all of the deep wells may be needed and not all of them would be installed 

initially.); 

 the trunkline (which would actually be constructed in stages as the mine 

units are brought on-line); and 

 access road improvements. 

The area of vegetation disturbance (primarily vegetation removal) during Initial 

Construction is about 95 acres (rounded to closest 5 acres). Approximately 80 

percent of this disturbance is in the Upland Big Sagebrush Shrubland, with the 

rest, about 20 percent, in the Lowland Big Sagebrush Shrubland. 

During Mine Unit Development, most of the surface disturbance would result 

from activities related to drilling of injection, production and monitor wells and 

construction of pipelines, header houses and necessary access roads. During 

Mine Unit Development, the impacts would be similar to those during Initial 

Construction, 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 vegetation 

disturbance during Mine Unit Development, the mine unit facilities are listed 

below and in Table 4.5-1: 

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 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 area of vegetation disturbance (primarily vegetation crushing in the pattern 

areas) during Mine Unit Development is on the order of 240 acres. All but about 

85 percent of this disturbance is in the Upland Big Sagebrush Shrubland, with the 

rest, about 15 percent, in the Lowland Big Sagebrush Shrubland. Based on the 

Project schedule presented in Figure 2.1-8, about 50 acres of disturbance would 

occur during the development of MU1, which would be at about the same time as 

the Initial Construction of the life-of-Project facilities. Approximately another 95 

acres of disturbance would occur about two years later, during development of 

Mine Unit 2; and another 95 acres two years after that for Mine Unit 3. 

Based on available information, an additional 15 acres would be disturbed for 

Mine Unit Development in the KM Horizon because the underlying KM Horizon 

ore body footprint is similar to the HJ Horizon. Therefore, the total disturbance 

area is 345 acres (330 acres for the Initial Construction and Mine Unit 

Development in the HJ Horizon and 15 acres for Mine Unit Development in the 

KM Horizon). A more detailed assessment of the surface disturbance related to 

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

revision to WDEQ-LQD. 

Section 4.6 of the NRC SEIS discusses the impacts to ecological resources in the 

Permit area, including impacts on the vegetation in the area. While vegetation 

would be removed as a result of the Construction activities, the small percentage 

of affected area makes the overall impact small (NRC, 2011a). 

4.8.4.2 Operation 

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

The NRC SEIS states in Section 4.6.1.2.1 that the impacts to vegetation during 

the Operation phase would be minimal since most of the land used was cleared 

during the Construction phase (NRC, 2011a). 

4.8.4.3 Reclamation 

The Reclamation phase includes the progressive Mine Unit Reclamation and the 

Final Reclamation. During Mine Unit Reclamation, disturbance would again 

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occur during some activities, e.g., when wells are abandoned and pipelines are 

removed from reseeded areas. However, this ‘re-disturbance’ of the same areas, 

e.g., a pipeline corridor, is not counted twice in the assessment of the acres 

disturbed. 

There should be no additional vegetation removal or crushing during Final 

Reclamation. Disturbance of reseeded areas, e.g., pipeline corridors, would occur 

during some activities, but, as mention above, this ‘re-disturbance’ is not counted 

twice. As the areas are reseeded with the permanent seed mix, there could be 

changes in the proportion of various species, including an increase in weeds. 

Section 4.6 of the NRC SEIS discusses the impacts to ecological resources, 

including vegetation in the area. New damage from reclamation may result from 

spills or leaks during the decommissioning process, but with the mitigation 

measures this is not expected to be significant. However, the NRC discusses 

some concern that the slow reestablishment of sagebrush shrubland and the 

woody plant species could lead to slightly more significant impacts (NRC, 

2011a). 

4.8.5 Vegetation Impacts from Other Alternatives 

4.8.5.1 No Action Alternative 

Under the No Action Alternative, surface disturbance would be avoided and there 

would be no impacts to surface vegetation related to the Project. Impacts from 

other existing activities, such as cattle grazing, mineral exploration, recreation, 

and hunting would continue. 

4.8.5.2 Not Fencing the Pattern Areas 

There would be a slight reduction in the acres of vegetation disturbance if the 

fences around the patterns areas were not constructed. However, the mitigation 

measures in the pattern areas, specifically reseeding, would be adversely 

impacted, as the new vegetation growth in the reseeded areas would be preferred 

by livestock and wild horses. 

4.8.5.3 Drying Yellowcake On-Site Alternative 

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

as the dryer would be within the Plant footprint. 

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4.9 Wildlife 

4.9.1 Agency-Required Measures 

This section describes the agency-required measures that would be included in the 

Proposed Action for the protection of wildlife in and near the Permit Area. All 

wildlife management practices were established in conjunction with the BLM, the 

WGFD and the USFWS guidelines and are designed to be consistent with 

regional recommendations by land and wildlife management agencies (BLM, 

2008c; WGFD 2008b; and WGFD 2009). The Wildlife Protection Plan for the 

Project is included in Attachment OP-6 of the WDEQ-LQD Permit to Mine, and 

correspondence with the USFWS and the WGFD about these Plans is provided in 

Addendum OP-A6-A of that attachment (LCI, 2011b). Standard construction, 

erosion control, and other BMPs described in other sections of this EIS would 

also help to minimize wildlife impacts. 

Particular attention was given to protection measures for Greater sage-grouse, as 

the Project is located on the edge of the South Pass Greater sage-grouse Core 

Breeding Area (WGFD, 2008b), as shown on Figure 3.8-5. However, many of 

the mitigation measures that would be implemented for the protection of Greater 

sage-grouse would mutually benefit other species of concern in the Permit Area. 

The measures for Greater sage-grouse were adapted from the Core Population 

Area Stipulations (WGFD, 2008b) and the stipulations developed by the Sage 

Grouse Implementation Team (SGIT) (Mead, 2011) to be practical in an ISR 

environment. The stipulations and their application are included in Table OP-A6­

1 of the WDEQ-LQD Permit to Mine (LCI, 2011b). A detailed assessment of the 

impacts on Greater sage-grouse using the SGIT Stipulations is included in 

Section 4.9.5.3 of this EIS. 

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

measures were added (Section 4.9.1.10). The first measure addresses continued 

consultation with agencies and incorporation of annual monitoring data through 

an Adaptive Management Plan. The second and third measures relate to new 

fence construction (Section 4.9.1.2) and address potential discrepancies between 

the BLM and WDEQ-LQD fencing criteria. Fences would be constructed 

according to the 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. The fourth measure pertains to 

water quality in the Storage Ponds and the protection of waterfowl (Sections 

4.9.1.4 and 4.9.1.6). 

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4.9.1.1 Road and Right-of-Way Measures 

The East and West Access Roads would be upgraded and access roads within the 

Permit Area would use existing two-track roads to the extent possible to help 

minimize new disturbance of sagebrush habitat. The roads would be upgraded or 

constructed following the BLM and the WGFD recommendations to minimize the 

road width, revegetate road shoulders, and limit vehicular speeds. 

All employees and contractors would be trained to recognize types of wildlife in 

the area, their susceptibility to disturbance or to collisions with motor vehicles, 

and measures that should be taken to avoid disturbance and wildlife/vehicle 

collisions. Speed limits within the Permit Area would be set based on the 

following considerations: the condition of the road, design of the road, safety 

factors, protection of equipment, wildlife and livestock protection, and dust 

protection measures. Generally, the speed limit on main roads would be 30 miles 

per hour and, on secondary roads, the speed limit would be 20 miles per hour. 

However, in no case would the speed limit be greater than 30 miles per hour. All 

employees would receive training regarding speed limits during indoctrination 

training. Site visitors would be advised of the Permit Area speed limits during 

site-specific training. Speed limit signs would be posted on the main roads with 

the permission of the BLM. 

An additional protective measure that may be implemented in concert with the 

BLM would be to gate or sign existing two-track roads that are adjacent to the 

main access road and Plant in order to help prevent additional traffic disturbance 

in the area. Project personnel travel outside of primary construction and drilling 

areas would be minimized through education and required use of main and 

secondary access roads. 

4.9.1.2 Fencing and Screening Measures 

Mine unit pattern areas would be fenced with standard wildlife-friendly fencing 

based on the BLM Manual Handbook 1741-1, Fencing (1989), which would keep 

cattle and wild horses out but would allow the passage of pronghorn and other 

wildlife. In order to mitigate Greater sage-grouse collisions with fences, fence 

markers would be installed on new fence lines to increase the visibility of the 

lines. New fences would also be monitored for evidence of Greater sage-grouse 

strikes. The fences would be removed after ISR operations are complete and 

vegetation has become re-established in accordance with permit requirements as 

described in Section RP 4.5.4 of the WDEQ-LQD Permit to Mine Reclamation 

Plan (LCI, 2011b), unless otherwise approved by the BLM. Access to the fenced 

areas would be through gates (e.g., at the Storage Ponds). Because there is the 

potential for gates to be inadvertently left open on occasion, pitless cattle guards 

or automatic gates may be installed to prevent cattle and wild horses from 

entering an open gate and becoming trapped in the fenced area. 

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All mud pits outside of fenced areas would be fenced during the drilling phase, 

while the pits are open. 

The Plant and Storage Ponds would be fenced for the duration of the Project. The 

fence around the Plant would be standard wildlife-friendly fencing based on the 

BLM Manual Handbook 1741-1, Fencing (1989). The fence around the Storage 

Ponds would enclose two acres of land and be constructed to prevent access by 

terrestrial mammals and to improve safety (Type II fencing per WDEQ-LQD 

Guideline No. 10 [1994c]). The Storage Ponds would be monitored daily for 

wildlife morbidity and mortality. If evidence of mortality were present, additional 

measures may be taken to prevent access. Additional deterrents would be 

consistent with agency recommendations. 

4.9.1.3 Transmission Lines 

The proposed pipelines, transmission line, and any other utilities would be placed 

in or adjacent to the access road right-of-way to help minimize habitat impacts 

where possible. To prevent the electrocution of raptors, the primary and 

secondary transmission lines and power poles would be built to the latest 

approved methods (APLIC, 2006). This would include cross-arm and transformer 

design. Tertiary transmission lines would be buried for employee safety, which 

would also minimize risks to raptors and large birds. In addition, to discourage 

roosting by raptors and corvids (and, in turn, increased predation of Greater sagegrouse), appropriate anti-perching and anti-roosting devices would be placed on 

power poles and cross-arms. The design would follow the BLM guidelines (Oles, 

2007) or other appropriate guidelines. 

4.9.1.4 Disease 

To reduce the threat of mosquito-borne illnesses in wildlife, LCI would treat the 

two Storage Ponds with an approved insecticide to prevent mosquito hatches. 

The BLM would require the applicant to obtain a Pesticide Use Proposal with 

associated environmental analysis and consider other Integrated Pest Management 

techniques, prior to authorizing the use of pesticides. Drilling mud pits would be 

backfilled as soon as possible after use in order to eliminate their use by 

mosquitoes. Equipment and materials would be stored in a manner that 

minimizes the accumulation of stagnant water. Used tires would be disposed of 

as they were generated or would be stored in a manner that prevents accumulation 

of water until taken off-site for disposal. 

4.9.1.5 Wildfire 

LCI would implement procedures to minimize the likelihood of starting a wildfire 

(including Hot Work Permits, Site Inspections, and Proper Storage of Waste). All 

field personnel would be trained in Emergency Response Procedures, including 

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reporting of fires. ISR uranium facilities generally use plastic piping; therefore, 

minimal welding and cutting takes place in the field. In addition to the 

preventative measures described in the NRC Technical Report (e.g., Sections 

5.7.1.4 and 7.6) (LCI, 2010), LCI would have a supply of fresh water from the 

water supply wells (Section 4.7.5.1) that could be used to help with wildfire 

suppression, if necessary. 

LCI would not use prescribed fires or weed burners to remove vegetation or to 

control invasive species unless prior approval was granted by the BLM and the 

WGFD. 

4.9.1.6 Potentially Harmful Materials 

Several measures would be used to prevent exposure to potentially harmful 

materials, and should an accident occur, procedures would be in place to promptly 

remove/remediate any releases. All liquid chemicals and petroleum products in 

and around the Plant would be maintained within bermed areas sufficient to 

contain any potential spill. No bulk hazardous chemicals would be used in the 

mine units. The mining solutions would have a pH of around 8.0 and would not 

contain any petroleum-based chemicals or elevated levels of heavy metals that 

present an acute hazard to wildlife or employees. 

Any wildlife mortality that could be attributed to exposure to toxic substances 

would be reported immediately to the WDEQ-LQD (and other WDEQ divisions 

as necessary), the BLM, the USFWS, and the WGFD. The goal of such reporting 

would be to identify and resolve the problem as quickly as possible. 

As previously discussed, the water quality in the Storage Ponds would be 

monitored quarterly and whenever a process change may result in a significant 

change in water quality. The Storage Ponds would contain produced groundwater 

and process waters with a near-neutral pH. No petroleum-based products would 

be sent to the Storage Ponds. Due to implementation of fencing, deterrents, and 

the control of algae and plankton, the water quality in the Storage Ponds is not 

expected to pose a risk to birds. However, if selenium levels were to reach 0.02 

mg/L in the Storage Ponds, the operator would prevent birds from using the 

Storage Ponds. The mitigation measures used would be approved by the BLM 

and would be effective in preventing the potential mortality of any protected birds 

in accordance with federal and state regulations (in accordance with 43 CFR 

3809.401(b)(4)). 

4.9.1.7 Reclamation 

Reclamation would be practiced throughout the Construction and Operation 

phases. Disturbed surfaces would be revegetated at the next appropriate season 

using a temporary or permanent mix seed, depending on whether the area would 

be redisturbed (Section 4.8). LCI would continue to reclaim disturbed areas as 

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soon as possible after exploration and ISR activities to help ensure reestablishment of habitat, as described in Section RP 4.5 of the WDEQ-LQD 

Permit to Mine (LCI, 2011b). 

Weed control is an important issue for Reclamation and protection of existing 

habitats for Greater sage-grouse and other species, and plant communities. Weed 

prevention measures, following the BLM guidelines and recommendations, would 

be implemented (BLM, 1996b and 2008c). 

4.9.1.8	 Reduction of Human Disturbance and Incidental Loss of 

Wildlife 

All employees would be informed of applicable wildlife laws and penalties 

associated with unlawful taking and harassment of wildlife. Employees would 

also be trained to recognize types of wildlife in the area, understand exclusion 

areas and dates, and report unusual activity or sightings, accidents, and other field 

conditions related to wildlife. Adherence to rules and procedures established for 

wildlife and habitat protection, such as speed limits, traffic routes, would also be 

monitored to reduce disturbance and mortality. 

4.9.1.9	 Wildlife Closures and Timing Windows 

Both Greater sage-grouse and raptors have been identified by the BLM and the 

WGFD to have seasonal time periods where restriction of human activities can be 

particularly effective for the birds’ protection. The wildlife exclusion periods 

recommended by the BLM and the WGFD are presented in Table 4.9-1. 

Application of the seasonal timing restrictions to LCI’s activities, including 

exploration drilling and the Proposed Action (Initial Construction, Mine Unit 

Development, Operation, Mine Unit Restoration and Reclamation, and Final 

Reclamation) would be consistent with the provisions in the WDEQ-LQD Permit 

to Mine, as outlined below (LCI, 2011b). The permit provisions were determined 

to be in line with the SGIT EO, as verified through correspondence with the 

WGFD during the WDEQ-LQD permit development as well as during 

development of the BLM EIS. 

During exploration drilling, the standard timing restrictions would continue to be 

followed, unless otherwise approved by the appropriate agencies. As described in 

the WDEQ-LQD Permit to Mine (Table OP-A6-1 and Addendum OP-A6-1), 

Initial Construction would not commence during wildlife seasonal restriction 

periods; however, Initial Construction commenced prior to the annual start of the 

seasonal restrictions period could continue through the seasonal restrictions 

periods. The progressive Mine Unit Development, including delineation drilling, 

well installation, and construction of mine unit facilities, e.g., header houses, 

secondary access roads, and secondary transmission lines, which is essential to 

maintaining Production (Section 2.1.6), would continue year-round but would not 

be initiated during the seasonal restriction periods. The progressive Mine Unit 

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Restoration and Reclamation would also continue year-round but would not be 

initiated during seasonal restriction periods. Final Reclamation would commence 

prior to the annual start of the seasonal restrictions period but could continue 

through the seasonal restrictions periods. 

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Table 4.9-1 Surface Activity Restrictions for the Protection of Wildlife 

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4.9.1.10 Greater Sage-Grouse Protection 

A variety of protection measures would be implemented for Greater sage-grouse 

protection as required by the Governor’s EO for Greater sage-grouse (2011-05) 

(Mead, 2011). These measures include road design, traffic controls; fencing, 

habitat enhancement (on- and off-site), personnel scheduling, and facility 

maintenance, as described in more detail below. Furthermore, a detailed 

discussion of how the Project meets the SGIT (Mead, 2011) stipulations is 

included in Section 4.9.5.3. An Adaptive Management Plan would also be 

adopted, as outlined below. 

As previously discussed, access roads would follow existing two-track roads to 

the extent possible to help minimize disturbance of habitat. Road widths would 

be minimized, while still conforming to the International Fire Code, as requested 

by county zoning. 

Protection measures, such as reduced speed limits and watering the road, would 

be implemented to reduce the amount of dust generated, which would potentially 

affect palatability of sagebrush. 

In order to mitigate Greater sage-grouse collisions with fences, fence markers 

would be installed on new fence lines to increase the visibility of the lines. New 

fences would also be monitored for evidence of Greater sage-grouse strikes. 

Adaptive Management 

In addition to the above mentioned protection measures, per Mead (2011), the 

following adaptive management plan, as requested by the WGFD, would be 

implemented to manage Greater sage-grouse populations within the area of 

impact of the Project. 

Baseline data have been collected from 2007 through 2011, providing a reference 

to compare future population trends and habitat use. The baseline data collection 

protocol established both an impact zone and a control area for Greater sagegrouse for the Project. The impact zone is simply defined as the area within a 4.0­

mile buffer surrounding the Permit Area, which currently includes 15 leks. The 

area outside of a 4.0-mile buffer would not be disturbed by Project activities and 

would be the control area. The control area currently contains 39 Greater sagegrouse leks. Leks in the impact and control areas would continue to be monitored 

through development and on into, and through production. Monitoring of leks 

would follow the protocol established in concert with the WGFD, as included in 

Attachment OP-6 of the WDEQ-LQD Permit to Mine (LCI, 2011b). As new leks 

are discovered within the impact or control areas, they would be included in the 

analyses. 

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A technical advisory committee (TAC) consisting of the BLM, the WGFD, the 

proponent, and appropriate consultant(s) would be created. The TAC would meet 

on an annual basis, and as called upon by the proponent, to review and discuss the 

annual wildlife report findings related to Greater sage-grouse. The report would 

include, at a minimum, the past year’s lek monitoring data. Lek attendance would 

be summarized at impact area leks and control area leks on an annual basis. 

Trends would be determined across three-year running averages, comparing 

impact area leks to control area leks. If a decline were observed at impact area 

leks as compared to control area leks (using a three-year running average during 

any five-year period), the trends would be analyzed to determine statistical 

significance and to determine if the downward trend was likely attributable to 

Project activity. If so, this would indicate that an impact threshold has been 

reached. The TAC would discuss the appropriate protection measure(s) to apply 

in an attempt to reverse or minimize the impact(s). In the event that an impact 

was determined but the cause of the impact was not able to be determined, the 

TAC would discuss and implement protection measures with the assumption that 

the Project has some relation to the determined impact. It would be incumbent on 

the proponent to pay for a study to determine the actual cause of the determined 

impact if the proponent wished to avoid applying additional protection measures 

to the company’s operations. All additional protection measures would be 

monitored and their effectiveness analyzed via monitoring and analyses set forth 

in Attachment OP-6 of the WDEQ-LQD Permit to Mine (LCI, 2011b), during the 

annual meeting. If, after a two-year period, the additional protective measures 

showed no positive effect on the impacted leks, additional measures would be 

applied. This cycle would repeat until all possible protection measures were 

applied or the impacted leks showed a positive effect from the applied measures. 

In the event that the TAC was unable to reach a consensus, for example, over 

whether an impact threshold was reached or the necessity of imposing specific 

additional protective measures, the dispute resolution/appeal process as 

envisioned by the SGIT EO (Mead, 2011) would be followed. 

Based upon Greater sage-grouse research related to energy development, the most 

likely impacts would occur from human activity and disturbance. Primarily 

actions that are perceived by Greater sage-grouse either visually or auditorily 

would elicit a behavioral response from Greater sage-grouse. Thus, most 

disturbance issues would likely involve movement and noise. Traffic levels and 

speeds, traffic noise, machinery movement or noise, are examples of impactinducing factors. Thus, protective practices would include options that can help 

reduce or eliminate disturbance issues. Practices to consider include; setting 

vehicle speed limits, traffic timing, reducing traffic, or sound reduction 

techniques, as well as other protective measures discussed above. 

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Additional Protective Measures to be Considered Based on Results from 

Monitoring 

Based on available information, it can be conservatively anticipated that at least 

some Project activities within the Permit Area would negatively influence 

populations. Enhancement of selective habitats could be considered as an 

optional protective measure. Habitats to be prioritized for enhancement would be 

selected according to the analyses described in Section 4.9.2.4. Enhancement 

considerations would be based on patch-size and large spatial scales, in order to 

increase the probability of a population-level effect and would also focus on the 

seasonal habitat(s) most influenced by Project activities. For example, if suitable 

nesting habitat were most influenced, then habitat enhancements would focus on 

increasing grass height and cover within relatively dense sagebrush stands and 

maintaining that height and cover to the following nesting season as residual 

grass. This enhancement plan would be developed and implemented with the 

assistance of the BLM and the WGFD rangeland specialists. 

Greater sage-grouse show remarkable fidelity, especially to nesting locations, and 

it has been shown in a developing natural gas field that adult females would not 

vacate their nesting areas regardless of the level of development that occurs 

within those areas (Holloran, 2005). Because of this fidelity, maintaining 

individuals that are using habitats within the Small Greater Sage-grouse 

Monitoring Area (Section 4.9.2.4) may expedite recolonization of the Permit 

Area following completion of Production. Therefore, personnel activities that 

may disturb females using habitats would be curtailed (e.g., dogs must be leashed 

at all times, walking into undisturbed habitats would be discouraged, and speed 

limits would be strictly enforced). Trash and road kill would be collected on a 

regular basis to minimize corvid occurrence within the Small Greater Sage-grouse 

Monitoring Area. Whenever a nesting female were discovered, additional 

protective measures may be instituted, including but not limited to delaying or 

limiting Project activities close to the nest until the female left the area. 

Protective measures would be determined on a case-by-case basis, depending on 

factors such as proximity and timing relative to critical Project activities. More 

details on the protective measures described in this section are in Section 2.2 of 

Attachment OP-6 in the WDEQ-LQD Permit to Mine (LCI, 2011b). 

4.9.1.11 Raptor Protection 

Spatial and seasonal buffers recommended for the protection of raptors presented 

in Table 4.9-1 would be adhered to, as previously discussed. 

4.9.1.12 Wildlife Enhancements 

In coordination with the BLM and the WGFD, wildlife enhancements could be 

orchestrated in the Permit Area or in off-site areas that are not proposed for 

Operation or disturbance. These enhancements could include placement of new 

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raptor nest platforms, creation of new water sources, or habitat 

modifications/improvements to improve specific habitat conditions for Greater 

sage-grouse (Section 4.9.1.10) or other high interest species. All seeding used 

would be completed with native species; sagebrush would be included in all seed 

mixes. 

4.9.2 Wildlife Monitoring 

Monitoring of wildlife resources in and near the Permit Area would be completed 

on an annual basis throughout the life of the Project. The purpose of the annual 

monitoring would be to document wildlife resources, population trends, and 

habitat conditions to help minimize adverse impacts to wildlife. 

4.9.2.1 Annual Monitoring and Report 

Annual wildlife monitoring would be coordinated with the BLM Rawlins Field 

Office and the WGFD. Consultation with the BLM and the WGFD would be 

conducted prior to completing any annual survey work. Wildlife inventory and 

monitoring would be completed by the BLM or the WGFD biologists, or a thirdparty contractor paid for by LCI. 

An annual monitoring report would be prepared and submitted to the BLM, the 

WGFD, and other interested parties by November 15 of each year. The report 

would include: survey methods, results, any trends, an assessment of protection 

measures implemented during the past year; recommendations for protection 

measures for the coming year; recommended modifications to monitoring or 

surveying; and any recommendations for additional species to be monitored (e.g., 

a newly listed species). The Annual Wildlife Monitoring Report, data and 

mapping would be formatted to meet the WDEQ-LQD requirements. Only 

qualified wildlife biologists or ecologists would be employed for wildlife 

monitoring. 

In addition to the specific annual monitoring for wildlife, LCI would document all 

known instances where Project activities may have impacted wildlife (such as 

wildlife/vehicle collisions on roads, or other mortality within the Permit Area). 

Any large die-offs or other evidence of possible wildlife exposure to toxic 

chemicals would be reported immediately to the WDEQ-LQD (and other WDEQ 

divisions as necessary), the BLM, the USFWS, and the WGFD. A record of 

wildlife mortality would be kept at the Permit Area and included in the Annual 

Wildlife Monitoring Report. 

Monitoring and survey methods are designed to be consistent with standard 

protocol used by the WGFD (2007), and to also follow monitoring requirements 

and recommendations of the WDEQ-LQD (Wildlife Monitoring Requirements for 

Surface Coal Mining Operations). 

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Table OP-A6-6 in the WDEQ-LQD Permit to Mine (LCI, 2011b) includes the 

wildlife monitoring schedule, which is described in the following sections. 

4.9.2.2 General Wildlife 

No specific monitoring measures are proposed for most wildlife species. Any 

known mortality of sensitive wildlife species due to Project activities would be 

recorded and reported. Any large die-offs or other evidence of possible wildlife 

exposure to toxic chemicals would be reported immediately to the BLM, the 

WGFD, and the USFWS. Also, wildlife incidentally observed during wildlife 

surveys for the specific wildlife groups discussed below would be recorded 

annually. 

4.9.2.3 Big Game 

An annual record of all big game mortality due to fence entanglements, vehicle 

collisions, and other factors would be completed. Winter mortalities would be 

estimated each spring from observations taken during wildlife surveys and other 

mine activities. The data to be recorded include: species, date, probable cause of 

mortality, and location. A table summarizing big game mortality would be 

submitted in the Annual Wildlife Monitoring Report. 

If concentrations of pronghorn appear suddenly or if apparent migration blocks 

(fences, snow drifts along roads or other blocks) are observed, the local WGFD 

personnel would be notified immediately. Any big game concentrations or 

migration blocks would be reported in the Annual Wildlife Monitoring Report. 

4.9.2.4 Greater Sage-Grouse 

The Greater sage-grouse monitoring protocols presented here are designed to 

assess the effects of Project activities on: Greater sage-grouse populations; 

seasonal habitat selection; and productivity within the Greater Sage-grouse 

Monitoring Areas ( Figure 4.9-1). Section 4.9.1.10 discusses how the 

Greater sage-grouse monitoring data would be used for adaptive management. 

As previously noted in Section 3.8, the Greater Sage-grouse Monitoring Areas are: 

 The Small Greater Sage-grouse Monitoring Area, which is delineated to 

conservatively establish the area where nesting and early brood-rearing 

females may be influenced by Project activities; and 

 The Large Greater Sage-grouse Monitoring Area, which is delineated to 

maximize the probability that control leks would be included. Control 

leks are considered to be leks within and/or near Core Area boundaries 

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that are not influenced by the Project, major highways, or other 

anthropogenic activities, except livestock grazing and public recreation. 

LCI would use lek search and lek count protocols to assess potential impacts of 

Project activities on Greater sage-grouse populations. The objective of lek counts 

is to track the male breeding population size within the Greater Sage-grouse 

Monitoring Areas throughout the life of the Project. The objective of lek searches 

is to determine if new leks become active within the Greater Sage-grouse 

Monitoring Areas during the life of the Project. 

To determine the potential effects of the Project on habitat selection, LCI would 

model the seasonal habitats existing within the Small Greater Sage-grouse 

Monitoring Area. The objectives of these models are to quantify the amount of 

habitat functionally influenced by the Project on a seasonal basis (e.g., nesting, 

early brood-rearing, summering and wintering habitats). 

LCI would use brood survey routes and wing surveys to assess potential Project 

impacts on Greater sage-grouse productivity. The objective of both surveys is to 

track chick productivity of females potentially influenced by Project activities 

throughout the life of the Project. 

Greater sage-grouse surveys discussed below would follow the standard protocol 

as recommended by the WGFD Greater Sage-grouse Technical Committee and by 

Connelly et al. (2003). 

This comprehensive Greater sage-grouse monitoring plan is designed to 

accomplish definitive monitoring of the effects of Project activities on Greater 

sage-grouse. The monitoring would lead to and guide effective protection 

actions. However, it is a cost intensive, long-term commitment and is timed to 

establish baseline conditions. Should a situation arise that prohibits or 

significantly delays LCI’s activities (before or after regulatory approvals for the 

Project are issued), the commitment may be curtailed and may be limited to only 

the required annual lek counts within the Small Greater Sage-grouse Monitoring 

Area. LCI would inform the WGFD, the BLM, the WDEQ-LQD, and the NRC 

should this monitoring change be necessary. 

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Populations 

Lek Counts 

Lek count data would be the primary data used to assess the population-level 

effects of developing the Project. The lek monitoring methods are therefore as 

comprehensive as possible. The objective of lek count monitoring is to track, as 

inclusively as possible, male breeding populations on leks potentially influenced 

by Project activities concurrent with leks not influenced by such activities but 

similar in other aspects throughout the life of the Project. 

Counts would be conducted at all known leks within the Greater Sage-grouse 

Monitoring Areas starting with the 2010 baseline list of known leks established 

from existing data (e.g., the WGFD Greater sage-grouse database) and a 

comprehensive lek search of the Greater Sage-grouse Monitoring Areas 

conducted in April 2010. The list of known leks would be updated on a threeyear cycle based on lek search flight results. 

All known leks within the Greater Sage-grouse Monitoring Areas would be 

counted annually. This number of leks may increase, depending on results of lek 

searches conducted throughout the life of the Project; however, the number would 

not be decreased from the 2010 baseline unless leks are established as 

‘unoccupied’ following protocols outlined by the WGFD Greater Sage-grouse 

Technical Committee. LCI would coordinate monitoring efforts with the BLM 

and the WGFD to avoid duplicative efforts and, as a result, undue disturbance of 

the leks. The count methodology that LCI would use is outlined below. 

The general lek count methodology is as follows: 

	 Counts would be conducted during the month following the peak of 

mating activity (April 1 to May 7). Research has shown that the highest 

number of male Greater sage-grouse is observed during this period. The 

increased number of males is due to young males showing up later in the 

strutting season even though most of the breeding has already occurred. 

	 Counts would be conducted from the ground as close to sunrise as possible 

and extended for one-half hour after sunrise. The phase of the moon may 

affect lek use patterns. During a full moon, Greater sage-grouse may 

display at night and consequently terminate activities earlier in the 

morning. This variation in activity may influence the choice of counting 

dates. 

	 Counts would be conducted a minimum of three times each year for each 

lek (at least one count every seven to ten days). 

	 All leks within a lek complex would be counted on the same day, with lek 

complexes estimated from spatial orientation of leks within the Greater 

Sage-grouse Monitoring Areas. 

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	 Counts would be completed on days with good weather conditions. 

Optimum weather conditions for counts are clear, calm days. Wind 

speeds should be less than 20 mph because high winds reduce lek activity. 

Temperature seems to have little effect on activity. Weather conditions 

would be recorded during each count. 

	 Known lek locations would be sited in mid-day periods prior to 

completing any counts. Access routes and counting points would be 

predetermined to allow the observer to count the lek without disturbing 

birds by driving or hiking. Counts would be made by using binoculars and 

spotting scopes from observation points. Observation points for each lek 

would be established and noted and each lek would be counted from these 

points in subsequent years. 

	 The location of each lek would be accurately determined and recorded 

using the Universal Transverse Mercator geographic coordinate system 

and the North American Datum 83. Observers would not disturb Greater 

sage-grouse to obtain lek locations. If a lek were active, the observers 

would make the best estimate of the lek location and return later to 

confirm. 

	 Data would be recorded on the standardized statewide reporting form. 

Lek Searches 

Breeding Greater sage-grouse may be displaced by some Project activities and 

thereby occupy other existing active leks or form new leks farther from those 

activities. Thus, lek searches would be required to accurately assess the 

population-level response of Greater sage-grouse to Project activities. 

During the peak breeding period in April, a systematic search for leks within the 

Greater Sage-grouse Monitoring Areas would be conducted from the ground to 

ensure the baseline survey is as thorough as possible. Ground searches would be 

conducted from 0.5 hours prior to sunrise to 1.5 hours after sunrise. If the April 

full moon coincides with the peak breeding period, additional searches throughout 

the nights with good moonlight would be conducted. The ground at all potential 

leks would be searched once the birds have left the site for evidence of consistent 

use (e.g., fecal droppings and feathers). Ground searches for leks can be more 

effective than aerial searches due to the birds’ reaction to aircraft (crouching), 

which makes the birds difficult to see and thus the leks difficult to identify, 

especially smaller leks. Ground searches can also be more effective as a result of 

focusing all locating techniques, such as listening and habitat inspection. 

Additionally, as Greater sage-grouse display all night during the full moon at the 

peak of the breeding period, night surveys can be effective at finding leks by 

sound. 

Lek searches of the Greater Sage-grouse Monitoring Areas would be conducted 

from fixed-wing aircraft every third year following the establishment of baseline 

data (i.e., 2013, 2016, and continuing through the Project). Searches would be 

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conducted during the peak of the breeding period between 0.5 hours before and 

1.5 hours after sunrise. Transects (approximately 1.0 kilometer [0.6 miles] apart) 

would be flown along north-south lines. Flights would be limited to days with 

good visibility and weather. Transects would be flown from approximately 100 

to 150 meters (328 to 492 feet) above ground level. Return visits from the ground 

to all potential new sites would be conducted to confirm a location as a lek as 

soon as feasible following aerial searches. If a new lek were found, it would be 

added to the known lek list and counted annually. Although, counting of new leks 

during the year of discovery would be initiated later in the breeding period (i.e., 

after the lek search), since maximum male attendance generally occurs after the 

peak of breeding due to the behavior of yearling males (thus counts should not be 

biased). 

As noted above, aerial searches may not be as effective as ground searches; 

however, ensuring the data are collected in a standardized manner throughout the 

life of the Project would be critical. Aerial searches do not require the same level 

of experience as a ground-based search and logistical considerations are less 

daunting. Therefore, aerial searches would increase the likelihood that 

comparable data would be collected throughout the life of the Project. 

In addition to determining Project-related impacts on Greater sage-grouse, lek 

data would also be used to assess the extent of impacts attributable to non-Project 

related activities such as other energy development project activities, grazing, and 

non-Project related traffic. Lek data would also be used to focus any potential 

Greater sage-grouse habitat enhancements on areas used by birds and most 

impacted by the Project. Section 2.2.1.3 of Attachment OP-6 in the WDEQ-LQD 

Permit to Mine (LCI, 2011b) describes these analyses in detail. 

Habitat Selection 

Non-invasive techniques for monitoring Greater sage-grouse nesting and early 

brood-rearing habitat selection and success are limited to radio telemetry 

(Spotlight capture and collaring of females during the peak of breeding appears to 

have negligible effect on subsequent behavior [Holloran, M. Personal 

communication. January 2010]). However, given the potential reaction of 

females to Project activities, the probability of maintaining a sample of radioequipped birds in areas affected by Project activities throughout the life of the 

Project may be low (deduced from Walker et al., 2007). Therefore, for the 

purposes of designing the monitoring program, it has been assumed that uranium 

extraction in the Permit Area would have an influence on nesting and early broodrearing females similar to the influence of natural gas development. 

Information from nesting female long-term reactions to natural gas development 

suggests that the area within one kilometer (0.6 miles) of infrastructure associated 

with energy development is functionally lost as nesting habitat (Holloran et al., 

2010). Holloran et al. (2010) also report that Greater sage-grouse females in 

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Wyoming rear their broods during the early brood-rearing period within 1.65 

kilometers (1.0 mile) of their nest. Thus, the amount of nesting and early broodrearing habitat that would be influenced by developing the Project would be 

conservatively estimated as all suitable habitats within the Permit Area and within 

2.65 kilometers (1.65 miles) of the Permit Area. Additionally, Ur-E’s (LCI’s 

parent company) two-year proposed exploratory drilling plan suggests activity 

south and southeast of the Permit Area. In anticipation of future actions (Section 

5.1.1), LCI would buffer this area of proposed activity by 2.65 kilometers and 

include this as potentially impacted habitat (i.e., as part of the Small Greater Sagegrouse Monitoring Area). Given the nature of exploratory drilling, this portion of 

the Small Greater Sage-grouse Monitoring Area may be modified to reflect onthe-ground activities that may occur and differ from proposed future plans. 

To establish suitable habitats within the Small Greater Sage-grouse Monitoring 

Area, LCI began seasonal habitat selection monitoring in 2010, and continued the 

monitoring in 2011, using radio-equipped female Greater sage-grouse. Data from 

2010 and 2011 were summarized in the annual monitoring reports (LWR 

Consultants, Inc. and Wyoming Wildlife Consultants, Inc., 2011 and 2012, 

respectively), and the 2012 monitoring is being completed. Thirty-six female 

Greater sage-grouse were captured in April 2010 from nine leks closely 

associated with the Permit Area using spotlighting and hoop-netting techniques. 

Each captured female was: fitted with a 19.5-gram Advanced Telemetry Systems 

necklace-style radio-transmitter; identified as yearling or adult (at least two years 

old) by shape of outermost wing primaries; and released at the point of capture. 

An additional 11 females had been collared in 2008-09 on leks situated in the 

southeastern portions of the Large Greater Sage-grouse Monitoring Area for a 

research project being conducted through the University of Wyoming. These females 

were also included in the monitoring. Starting in late April, pre-nesting females 

were located at least twice weekly to determine nest initiation. Nesting locations 

of radio-equipped females were found by circling the signal source until females 

were observed; nest sites were marked with a GPS to facilitate location 

identification following the completion of incubation. Incubating females were 

monitored at least twice weekly. 

Nest success (hatched or not) was assessed by visual examination of eggshell 

fragments after a female had left her nesting area. Conditions at unsuccessful 

nests were examined to determine the cause of failure. Females with broods were 

found twice between 5 and 14 days post-hatch to determine early brood-rearing 

habitat selection. At 14 days post-hatch, early brood-rearing success was 

determined (at least one chick alive 14 days post-hatch is a successful female); the 

existence of chicks was assessed either through direct visual confirmation of a 

chick, or through the reaction of the female to the researcher. Brooding females 

were located at least once per week from 14 days post-hatch through August. (It 

was expected that late brood-rearing habitat selection would be associated with 

mesic sites.) Barren females (e.g., females that were unsuccessful nesters or 

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brooders) were located at least monthly from nest or brood loss through August to 

determine seasonal habitats selection. 

From September through March, all radio-equipped Greater sage-grouse were 

located from fixed wing aircraft at least bimonthly. Reference transmitters (i.e., 

transmitters of known location deployed pre-flight by observers) were used to 

determine flight location accuracy. 

Seasonal habitat selection data (nest, early brood, late brood, summer, and winter) 

from the 2010 and 2011 monitoring would be used to generate Resource Selection 

Functions (RSFs) in a ‘used’ versus ‘available’ analysis. RSFs would be applied 

to map the suitable seasonal habitats existing within the Small Greater Sagegrouse Monitoring Area. For this analysis, it would be assumed that Project 

activities within the Permit Area would influence the total acreage of suitable area 

by season that occurs within the boundaries of the Small Greater Sage-grouse 

Monitoring Area. 

Productivity 

Three approaches would be used in evaluating Greater sage-grouse productivity: 

transects; wing barrels; and climate. 

Transects 

Late brood-rearing and barren female summer locations from radio-equipped 

birds would be used to identify areas where birds using nesting or early broodrearing habitats closely associated with the Permit Area concentrate during the 

summer. Eight permanent walking transects 1,000 meters in length were established 

in each of these areas. Transects were surveyed twice during a one-week period in 

late July from sunrise to two hours after sunrise to ensure feeding times were 

captured in the monitoring efforts. All Greater sage-grouse observed were counted 

and classified (adult male, adult female, young of the year). These 2010 established 

transects would be surveyed annually through the life of the Project. Data collected 

from these efforts would be compared by total Greater sage-grouse use by sex and 

numbers of chicks per female. 

Wing Barrels 

LCI would work with biologists from the WGFD to establish wing-barrel 

locations to further investigate annual differences in productivity relative to 

Project activities. Wing barrels with signs designed to explain the reasoning for 

monitoring have been placed at access routes to areas where females closely 

associated with the Permit Area are located during nesting or early brood-rearing 

summer (treatment area). A comparable area in terms of available summering 

habitats and spatial scale would also be monitored in this fashion to act as a 

control. Barrels would be placed and monitored each hunting season throughout 

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the life of the Project. Wings collected from these barrels would be compared 

(treatment versus control area) by the number of chicks per female in the harvest. 

Climate 

Seasonal weather patterns may dictate Greater sage-grouse use of traditional 

summering areas. In particular, brood-rearing females would remain in the 

Upland Big Sagebrush Shrubland habitat until range desiccation would force them 

onto more mesic sites. Seasonal weather data would be used to assist in assessing 

the potential effects of this behavior on productivity results. 

4.9.2.5 Raptors 

Annual monitoring of known raptor nests would be completed each spring 

between April and July to determine nest status. Nest surveys would be 

completed from the ground. 

A ground survey of the Permit Area and surrounding one-mile radius would be 

completed during the first two weeks of February each year for signs of golden 

eagle and great-horned owl nesting and/or courtship. Early courtship behavior 

would be documented in new nesting areas; and the BLM, the USFWS, and the 

WGFD would be consulted to determine appropriate protection measures. 

Three thorough surveys for nesting raptors would be completed for the Permit 

Area and surrounding one-mile perimeter through the spring. One survey would 

be completed during March to locate great-horned owl and golden eagle nests. A 

second survey would be completed early in the raptor nesting season. Field 

surveys for potential nesting raptors within 0.5 miles of existing Project activities 

and those activities proposed for the coming year would be be conducted. The 

objective would be to document early courtship behavior in potential conflict 

situations, because, once eggs are laid, protective options become restricted. 

Reporting would indicate whether nesting territory is: not occupied (inactive); 

occupied by one raptor (active); or occupied by a pair (active). 

One survey would be completed from mid-May to mid-June to locate new raptor 

nests (nests that have become established since the April survey) and to check the 

status (activity, number of young birds) of all nests. Follow-up visits to 

previously identified nests would be timed to facilitate documentation of nesting 

activity, according to the biology of the species present and variations in breeding 

chronology, including: nest building; reproductive attempts and success; and 

fledging success. The status and productivity of the nests would be reported 

annually by location, nest type and characteristics, species, and number of fledged 

birds. 

Nest surveys would be completed from the ground. Nest checks would be brief 

and conducted to avoid flushing incubating raptors. 

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The linear distance of each nest site (active and inactive) from the nearest known 

regular human or equipment activity would be determined each breeding season. 

The presence of visual barriers (i.e., direct line of site blocked between the 

disturbance and the nest) would be noted. It would be determined if the 

activity/disturbance is unrelated or related to Project activities. This information 

would be shown on a raptor monitoring map in the Annual Wildlife Monitoring 

Report. 

4.9.2.6 Migratory Birds of High Federal Interest 

Nesting non-game bird surveys would be conducted in representative 

vegetation/habitat types within the Permit Area. These surveys would be used to 

document breeding MBHFI that are present in the area. 

Surveys would follow techniques recommended by the WDEQ-LQD (1994b). 

Two transects would be established in each vegetation type of the Permit Area. 

Transects would be 1,000 meters (0.62 miles) in length (2,000 meters [1.24 miles] 

per habitat type – Upland Big Sagebrush Shrubland and Lowland Big Sagebrush 

Shrubland). In both vegetation types, 100-meter- (328-foot-) wide belt transects 

would be walked. Birds (including non-game and non-MBHFI birds) observed or 

heard would be recorded. Transect start and stop points would be located by 

GPS. Transect locations would be shown on a 1:24,000-scale quadrangle map. 

Surveys would be completed during the peak of the nesting season, during the 

first week of June. Surveys would be completed from 0.5 hours before sunrise to 

9:30 AM. 

4.9.2.7 Threatened and Endangered Species 

Federally Listed or Candidate Species 

Any observation of a federally listed (T&E) species would be recorded and 

promptly reported. Any mortality of a listed species would be reported to the 

USFWS within one day of discovery. 

If new species (that are present in the Permit Area) are listed as threatened or 

endangered during the Operation phase, the USFWS would be consulted to 

develop specific protection and monitoring measures. 

BLM Special Status Species 

Pygmy Rabbits 

Based on current wildlife inventories, Pygmy rabbits are restricted to the Lowland 

Big Sagebrush Shrubland habitat within the Permit Area. Pygmy rabbits would 

be surveyed using techniques described by Ulmschneider (2004). Four transects 

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would be established in Pygmy-rabbit-occupied lowland sagebrush swales within 

the Permit Area. Lowland sagebrush occurs in narrow swales and drainages of 

the Permit Area. The transect length (from the start point to the stop point) would 

be 0.5 miles. Transects would not be linear but would meander through the 

habitat area. Meandering transects would start and end at the same points each 

year. Data would be recorded on standard data forms using the recommended 

data recording methods (Ulmschneider, 2004). Annual transect tracts would be 

recorded and presented on a map in the Annual Wildlife Monitoring Report. 

4.9.2.8 Lagomorphs 

Prey abundance would also be monitored. Desert cottontail and white-tailed 

jackrabbit populations would be evaluated using spotlight surveys through native 

habitat in the Permit Area. Surveys would be completed at night as close to the 

full moon as possible. One survey would be completed in June and another 

survey would be completed in August of each year. Transects would be 

established along approximately 1.5 miles of road within the Permit Area. Once 

reclaimed areas were established, transects would be established in these areas. 

All transect locations would be presented on a map in the Annual Wildlife 

Monitoring Report. 

4.9.3 Impact Significance Criteria 

Habitat loss or alteration, incremental habitat fragmentation, displacement of, and 

stresses on, wildlife, and direct and/or indirect mortalities were considered in 

order to assess the significance of impacts on wildlife. The availability of, and 

proximity to, the same or similar habitat, as well as the size of the population 

were also used to evaluate the significance of impacts on wildlife. 

The Rawlins RMP Management Goals for wildlife focus on maintaining a 

functioning habitat to support and sustain native populations. The significance 

criteria used to address wildlife examine both the habitat availability and a healthy 

population size, which address the management goals of the Rawlins RMP. 

4.9.4 Wildlife Impacts from the Proposed Action 

A detailed discussion of the potential impacts to wildlife is provided in the 

following sections for each phase of the Project (Section 4.9.5 – Construction, 

Section 4.9.6 – Operation, and Section 4.9.7 – Reclamation). Because the 

majority of the wildlife species in the northeast portion of the Basin rely on 

sagebrush habitats for survival, they would generally be impacted in similar ways. 

Therefore, unless a unique impact to a particular species is anticipated, the effects 

of the Project on all wildlife are assessed as a whole. Wildlife species that could 

be uniquely impacted are discussed in detail in separate subsections, including: 

big game; Greater sage-grouse; raptors; waterfowl and shorebirds; MBHFI; T&E 

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species; and reptiles and amphibians. The impacts from the No Action 

Alternative and the Other Action Alternatives are evaluated in Section 4.9.8. 

Agency-required and additional measures and monitoring associated with the 

Proposed Action are discussed in Sections 4.9.1 and 4.9.2, respectively. 

During the life of the Project, a total of approximately 345 acres of wildlife 

habitat would be disturbed, which is approximately eight percent of the 4,254­

acre Permit Area. As outlined in Section 4.8.4, the disturbance is progressive. 

The two major vegetation/habitat types disturbed are the Lowland and Upland Big 

Sagebrush Shrublands. Of the acres disturbed, approximately 85 percent would 

be in the Upland Big Sagebrush Shrubland and approximately 15 percent would 

be in the Lowland Big Sagebrush Shrubland (Table 4.5-1). 

4.9.5 Construction 

The Construction phase includes both the construction of the Plant and other lifeof-mine facilities (Initial Construction) and the progressive construction of mine 

units during the Project (Mine Unit Development). The seven-month Initial 

Construction includes construction/upgrading of access roads/utility corridors, the 

Plant, the Storage Ponds, and the UIC Class I wells. Mine Unit Development 

includes exploration drilling, installation of monitoring wells, installation of the 

production and injection wells, and construction of the associated surface 

facilities. As construction of facilities were completed, surrounding areas would 

be reclaimed in order to minimize long-term disturbances. During Construction, 

potential impacts to wildlife include habitat disturbance/loss, stress due to 

increased noise from traffic and construction activities, and direct mortality from 

increased traffic and construction activities. 

4.9.5.1 General Impacts on Wildlife 

During Initial Construction, approximately 95 acres (rounded to the nearest five 

acres) would be disturbed (two percent of the total Permit Area). Of the acres 

disturbed, approximately 80 percent would correspond to disturbance of the 

Upland Big Sagebrush Shrubland and approximately 20 percent would 

correspond to disturbance of the Lowland Big Sagebrush Shrubland (Table 4.5-

1). These 95 acres of disturbed land would represent a long-term direct impact to 

a small percentage of the available wildlife habitat. During Initial Construction 

and throughout the life of the Project, approximately eight acres around the Plant 

would be restricted from cattle and wild horses, but not wildlife, and 

approximately two acres around the Storage Ponds would be fenced to restrict all 

wildlife (Section 2.1.2.6). Since only a small percent of the total Permit Area 

would be disturbed, wildlife is expected to disperse from the Permit Area ahead of 

sequential Construction and Operation. 

During Mine Unit Development, the habitat disturbance would be similar to that 

during Initial Construction, but the facilities being constructed would be smaller, 

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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. The total area of habitat disturbance during 

Mine Unit Development, which would consist primarily of vegetation crushing in 

the pattern areas, would be on the order of 240 acres. Approximately 85 percent 

of this disturbance would be in the Upland Big Sagebrush Shrubland, with the 

remainder, about 15 percent, in the Lowland Big Sagebrush Shrubland. 

Approximately 50 acres of disturbance would occur for the first mine unit, and 95 

acres for the next two mine units (Section 4.8). The pattern areas within these 

mine units would be fenced to restrict cattle and wild horses, but not wildlife, 

from entering (Figure 2.1-5 and Section 2.1.2.6). During drilling, mud pits 

would be fenced if they were located outside of the fenced portion of the mine 

units. Inside the fenced portion of the mine units, mud pits would not be fenced, 

in part due to the limited time the pits were open and the level of activity around 

the pits while they were open. Temporary mud pits have not been the cause of 

significant wildlife mortality at other ISR operations. If conditions were found to 

differ from those at other ISR operations, more protective measures, such as 

temporary fencing, would be evaluated. The ISR process is iterative; new mine 

units are brought into production as older mine units are reclaimed. Therefore, 

not all disturbance would occur at once and the disturbance would be clustered. 

In addition, as discussed in Section 2.1.5.1, disturbed areas would be reseeded as 

soon as possible after Construction and maintained through Operation to help 

minimize the duration of the disturbance. 

Species displaced during Construction would relocate to adjacent, undisturbed 

areas and likely return to their previously occupied habitats after Construction 

ended and suitable habitats were re-established. Small mammals and songbirds 

dependent on shrubs for food, nesting, and cover would be impacted most in areas 

where vegetation clearing would be needed for Construction. Birds are mobile 

and would likely disperse into adjacent areas with an abundance of similar 

habitat. The Lowland Big Sagebrush Shrubland habitat has the highest diversity 

and density of nesting birds and small mammals in the Permit Area (LCI, 2010); 

less than one percent of this habitat type in the Permit Area would be disturbed 

during Construction. In general, because only a small percentage of the total 

Permit Area would be disturbed, wildlife species are expected to disperse as 

Construction activities approach, minimizing the occurrence of direct mortality. 

However, direct mortality of smaller, less mobile species, such as passerine birds, 

amphibians, reptiles, and small mammals, could occur due to vehicle traffic or 

equipment use. Direct mortality is not expected to have a population-level effect. 

Sagebrush obligate species may be impacted indirectly due to decreased habitat 

effectiveness from increases in noise and traffic. Increased noise from 

Construction equipment could cause wildlife to relocate; however, equipment 

noise is expected to be indistinguishable from wind noise at the Permit Area 

boundary (Section 3.11). Therefore, noise from Construction activities would not 

affect wildlife receptors outside of the Permit Area and is not expected to impact 

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receptors in many parts of the Permit Area that are further from the Construction 

activities. 

During the Construction phase, increased heavy equipment would be transported 

to the Permit Area. Increased on-site traffic in the Permit Area could impact 

wildlife due to an increase in noise and an increased chance of direct mortality 

due to vehicle collisions. However, the volume of traffic associated with the 

Project is expected to be relatively small compared to the current traffic on nearby 

off-site roads. Due to the comparatively small workforce associated with the 

Project; and the restricted time of work hours, impacts to wildlife from increased 

traffic on-site and off-site would be negligible. 

Finally, sagebrush obligate species may also be affected from indirect impacts of 

the Project such as increased predation and competition, and reduced resource 

availability. Mitigation measures described in Section 4.9.1 would help to 

minimize these potential impacts. 

4.9.5.2 Big Game 

The Permit Area provides Winter/Yearlong Pronghorn Range and seasonal range 

for elk and mule deer. Elk and mule deer have been spotted only rarely in the 

Permit Area; thus, impacts to these species are expected to be minimal. 

Impacts to pronghorn may include loss and modification of habitat, increased 

mortality from increased traffic on local and regional roads, increased 

disturbances due to human presence, and increased poaching and/or harvest from 

improved access on newly constructed roads. At most, about eight percent of 

pronghorn habitat (Lowland and Upland Big Sagebrush Shrublands) in the Permit 

Area would be disturbed during the Construction phase. However, much of this 

disturbance would be short-term as the individual mine unit areas were reclaimed. 

Pronghorn have been shown to become habituated to increased traffic volumes 

and heavy equipment if the traffic and equipment move in a predictable way 

(Reeve, 1984). Construction activities and unpredictable traffic flows, however, 

may cause pronghorn to disperse from the area. Pronghorn displacement of up to 

0.6 miles has been observed from construction activities (Easterly et al., 1991). 

There is, however, adequate Winter/Yearlong Pronghorn Range habitat 

surrounding the Permit Area to accommodate this displacement and pronghorn 

may possibly return to the Permit Area once Construction activities were 

concluded. Impacts to pronghorn are expected to be minimal because the species 

is highly mobile and impacts are not expected to threaten the continued existence 

of the species’ population in the Permit Area and surrounding habitat. 

Section 4.6.1.1.1.2 of the NRC SEIS discusses the Project impacts to wildlife. 

Since no crucial habitats for big game animals are affected by the Construction 

and big game animals are mobile and can move to areas away from the Project, 

impacts on big game animals are expected to be minimal (NRC, 2011a). 

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4.9.5.3 Greater Sage-Grouse 

Impacts to Greater sage-grouse during Construction would include loss and/or 

modification of habitat from facility construction, fencing and increased 

disturbances due to human presence. The Greater sage-grouse leks found in the 

study area (Section 3.8.3.2) are located in the Upland Big Sagebrush Shrubland 

community in areas with cushion plants, blowouts and bare ground. Less than ten 

percent of this habitat in the Permit Area would be disturbed during Construction. 

Potential impacts from the Project are discussed below. 

The NRC SEIS, Section 4.6.1.1.1.2 discusses wildlife impacts from the Project, 

including impacts to Greater sage-grouse. Habitat could be destroyed and human 

activity could disrupt normal behavior of the bird. The NRC suggests that due to 

the protected nature of this bird, the effects from the Construction could have a 

larger impact, but with protective measures, could be mitigated (NRC, 2011a). 

The orientation of the Project facilities and existing Greater sage-grouse leks are 

shown on Figure 4.9-2. The Plant and the majority of the mine units are outside 

the two-mile buffers for the closest active and occupied leks, which are the Green 

Ridge Lek to the east and the Discover and Discover South Lek to the west. 

(Although the two-mile buffers are no longer applicable in Greater sage-grouse 

Core Areas, the buffers were recognized when baseline monitoring began in 2006 

[Section 3.8.3.2].) The necessary support facilities were sited, in part, based on 

distance from existing occupied Greater sage-grouse leks. In particular, the Plant 

was sited between the two-mile buffers for the closest active and occupied leks. 

The closest lek to the Permit Area (Crooked Well Lek) is considered Occupied ­

Inactive based on data from the last several years (Section 3.8.3.2 and Attachment 

D9-4 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). As discussed in Section 

4.9.1.10, the Proposed Action would include adherence to the SGIT stipulations 

(Mead, 2011 and Wyoming Interagency, 2011). Potential impacts to Greater 

sage-grouse were assessed in accordance with these stipulations and are discussed 

in detail below in order of Surface Disturbance, Surface Occupancy, Seasonal 

Use, Transportation, Noise, Overhead Lines, Vegetation Removal and Sagebrush 

Treatment, and Specific Stipulations. 

Assessment of Impacts on Greater Sage-Grouse using SGIT Stipulations 

Surface Disturbance 

As advised by the WGFD, LCI completed the Project Impact Analysis Area 

(PIAA) process (now known as the Density and Disturbance Calculation Tool 

[DDCT]) outlined by the SGIT stipulations (Mead, 2011 and Wyoming 

Interagency, 2011) in order to evaluate potential effects of the Project on Greater 

sage-grouse. Results of the PIAA/DDCT process and the WGFD review are 

documented in Appendix D. The analysis was sent to the WGFD for review. 

WGFD approved the way the analysis was carried out and commented that the 

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results indicated that the surface disturbance resulting from the Project was in line 

with the SGIT stipulations. In accordance with the PIAA-defined methodology, a 

PIAA boundary was determined (with a total area of 147,060 acres). A total of 

1,341 acres (including both proposed and existing disturbance) was determined to 

be the Maximum Disturbance based on the Project’s PIAA disturbance 

calculations, and includes the 330 acres of surface disturbance anticipated for the 

Initial Construction and development of the HJ Horizon. Therefore, the 

Maximum Disturbance would equate to 0.90 percent of the defined PIAA, which 

is less than the SGIT maximum disturbance stipulation of five percent. 

Habitat Assessment is critical to determining Maximum Disturbance. Habitat 

Assessment involves the collection of baseline Greater sage-grouse population 

data. To complete the Habitat Assessment, LCI initiated a detailed Greater sagegrouse monitoring program for the Project. During 2010, Greater sage-grouse 

telemetry was started along with other components of the Habitat Assessment. 

Sections 3.8.3.2 and 4.9.1.1 describe the Greater sage-grouse monitoring program 

that commenced in 2010 and would continue during the Project. The initial 

monitoring results are summarized in the Project’s 2010 and 2011 Annual 

Wildlife Monitoring Reports (LWR Consultants, Inc. and Wyoming Wildlife 

Consultants, Inc., 2011 and 2012, respectively)(Appendix C). This monitoring is 

also being completed as part of the Monitoring/Adaptive Response component of 

the SGIT General Stipulations (Stipulation No. 9). 

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Surface Occupancy 

According to the SGIT stipulations (Mead, 2011 and Wyoming Interagency, 

2011), there should be no surface occupancy within 0.6 miles of the perimeter of 

occupied Greater sage-grouse leks. One active lek (Discover) and one OccupiedInactive lek (Discover East) to the west of the Permit Area are within 0.6 miles of 

the West Access Road. The Discover South Lek is occupied, active, and just 

outside of the 0.6-mile buffer of the West Access Road. This road is currently a 

two-track road, and would be upgraded for Project use. Two active leks (Green 

Ridge and Sooner) to the east of the Permit Area boundary are within 0.6 miles of 

Sooner Road. Sooner Road is already an established road and no new surface 

occupancy would be associated with this road. The Green Ridge Lek is just 

outside the 0.6-mile buffer of the East Access Road. The Crooked Well Lek, 

which intersects the Permit Area boundary, is currently classified as OccupiedInactive (Section 3.8.3.2). Greater sage-grouse have not been observed at this lek 

for many years. As seen in Figure 4.9-2, this lek is within 0.6 miles of the East 

Access Road (existing currently as a two-track road). Seasonal restrictions 

(described in the section below) would be adhered to if this road were upgraded. 

As discussed above, three occupied leks, two Occupied-Inactive (Discover East 

Lek and Crooked Well Lek) and one occupied, active lek (Discover) are within 

0.6 miles of the access roads, which would be upgraded. This surface occupancy 

could impact the status of Greater sage-grouse occupation of these leks. This is 

contrary to the stipulations set forth in the SGIT; however, the EO does allow for 

exceptions to be considered on a case-by-case basis. Both the BLM and the 

WGFD staff attended a field site visit to the Permit Area. The three lek sites were 

visited and it was confirmed from being on-site that the natural topography 

blocked the pre-existing two-track road from view of the leks. This visit 

confirmed the finding of the viewshed analysis conducted by the proponent 

(Appendix E). The WGFD reviewed the potential impacts to Greater sagegrouse associated with upgrading the existing two-track road and determined that 

upgrading the existing two-track road to provide access to the Permit Area would 

have less impact to the Greater sage-grouse than creating a new road outside the 

0.6-mile lek buffer (WDEQ, 2011a). (Alternate routes considered for the East 

and West Access Roads are discussed in Section 2.3.3.8.) 

Seasonal Use 

In accordance with the SGIT stipulations (Mead, 2011 and Wyoming Interagency, 

2011), exploration outside of the mine unit areas and initiation of construction 

would take place only between July 1 and March 14 in areas outside of the 0.6­

mile perimeter of a lek in Core Areas where breeding, nesting, and early broodrearing habitat is present (Section 2.1.6.4). 

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Transportation 

According to the SGIT stipulations (Mead, 2011 and Wyoming Interagency, 

2011), main roads used to transport production and/or waste products should be 

located greater than 1.9 miles from the perimeter of an occupied Greater sagegrouse lek. Other roads used for access and maintenance should be greater than 

0.6 miles from the perimeter of an occupied Greater sage-grouse lek. As 

discussed in the surface occupancy section above, Sooner Road is a preexisting, 

established road, as is Wamsutter-Crooks Gap Road. The East and West Access 

roads are existing two-track roads, which would be upgraded. Any scheduled 

improvements to these roads would comply with seasonal restriction guidance 

provided by the SGIT. Wamsutter-Crooks Gap Road and the West Access Road 

would be used to transport production and waste. Three occupied leks, one 

Occupied-Inactive (Discover East Lek) and two occupied, active leks (Discover 

Lek and Discover South Lek) are within 1.9 miles of these roads. 

To assess the potential impact of the road use, topographical visual assessments 

and analysis of opportunity costs of habitat fragmentation due to implementation 

of new access roads were performed. The WGFD reviewed the potential impacts 

to Greater sage-grouse and determined that this option would have less impact to 

the Greater sage-grouse than creating new roads outside the 1.9-mile lek buffer 

(WDEQ, 2011a). (Alternate routes considered for the East and West Access 

Roads are discussed in Section 2.3.3.8.) Furthermore, the estimate increased 

production transport of one 18-wheeler truck per day was not expected to have 

significant impacts. Impacts from roads within 0.6 miles of leks are discussed in 

the surface occupancy section above. Increases in traffic would occur primarily 

during scheduled working hours, 7 AM to 5 PM, which overlap by one hour with 

the primary hours of concern for breeding Greater sage-grouse (6 PM to 8 AM) 

(Attachment OP-6 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). 

Noise 

Noise caused by traffic and Construction-related activity also may pose an 

adverse impact to Greater sage-grouse. Anthropogenic noise can reduce lek 

attendance and cause animal displacement. According to the SGIT stipulations 

(Mead, 2011 and Wyoming Interagency, 2011), noise should be limited to 10 

dBA above ambient noise measured at the perimeter of a lek from 6 PM to 8 AM 

during initiation of breeding (March 1 to May 15). The distance from occupied 

leks to areas of construction or traffic is at least 0.25 miles (1,320 feet), with the 

exception of Sooner Lek, which is approximately 300 feet from the existing 

Sooner Road. As discussed in Section 4.12, noise from heavy construction 

equipment would be indistinguishable from the ambient wind noise at a distance 

of 1,000 feet. Therefore, the adverse impacts of noise on Greater sage-grouse at 

most leks are expected to be negligible. However, given that the Sooner and 

Sooner Oil Leks are within 1,000 feet of Sooner Road, traffic increases along this 

road could impact lek attendance at these leks. 

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Sooner Road would not be expected to undergo any additional construction or 

improvements; therefore, any increase in noise in the vicinity of Sooner Lek 

would be a result of increased traffic use. It is expected that increases in traffic on 

Sooner Road would be primarily due to commuter traffic rather than 

transportation of heavy construction equipment, which would primarily use the 

Wamsutter-Crooks Gap Road. Therefore, the impacts to Greater sage-grouse 

from traffic noise were assessed using an approximate commuter traffic noise 

level. A summary of noise effects on wildlife populations (Federal Highway 

Administration, 2004) includes reference to measured average traffic noise levels 

at 50 feet (15 meters) of 54 to 62 dBA for passenger cars and 58 to 70 dBA for 

heavy trucks. Using the highest value of 70 dBA for the starting source, a 

calculation from Golden et al. (1979), and a distance of 300 feet., noise from 

heavy trucks would not exceed background noise levels (58 dBA at 200 feet). 

Furthermore, the bulk of increased traffic would not occur in the time frame of 

most concern for Greater sage-grouse (6 PM to 8 AM). 

Traffic on unpaved roads also creates dust and may reduce the palatability of 

sagebrush plants both in and out of the Permit Area boundaries. The increased 

traffic adjacent to the Sooner Lek could result in lower lek attendance if dust 

emissions were high. Dust emissions would be less of a problem, however, 

during the winter (due to increased precipitation/snow cover). 

Overhead Lines 

According to the SGIT stipulations (Mead, 2011 and Wyoming Interagency, 

2011), new power lines should be buried when possible. New overhead lines 

should be located at least 0.6 miles from the perimeter of occupied Greater sagegrouse leks and should be raptor-proofed. As shown in Figure 4.9-2, the power 

line for the Project would connect with the existing transmission line, which runs 

along the western boundary of the Permit Area. The new powerline would be 

located more than 0.6 miles from the nearest leks. Appropriate anti-perching and 

anti-roosting devices would be placed on power poles and cross-arms. Tertiary 

transmission lines within the Permit Area would be buried. In cases where 

transmission line burial were not an option, overhead lines would be constructed 

to current standards using publications such as those from the Avian Power Line 

Interaction Committee (2006). This would include cross-arm and transformer 

design. 

Vegetation Removal and Sagebrush Treatment 

In accordance with the SGIT stipulations (Mead, 2011 and Wyoming Interagency, 

2011), vegetation removal would be minimized and all topsoil and vegetation 

removal would occur between July 1 and March 14 in areas within 4.0 miles of an 

occupied lek. In accordance with the Rawlins Field Office RMP (BLM, 2008c) 

disturbance restrictions, no vegetation removal would occur within 0.25 miles of 

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occupied Greater sage-grouse leks and would occur only between July 16 and 

February 28 in Core Areas where breeding, nesting, and early brood rearing 

habitat is present. Furthermore, all requirements regarding the treatment of 

sagebrush would be followed. 

Specific Stipulations 

Specific stipulations relevant to the Project are: 

	 For development drilling or ore body delineation drilled on tight centers, 

(approximately 100 feet by 100 feet), the area of disturbance would be 

delineated by the external limits of the development area. Assuming a 

widely-spaced disturbance pattern, the actual footprint would be 

considered the area of disturbance. 

	 The number of active mining development areas (e.g., operating 

equipment and significant human activity) is not to exceed an average of 

one site per square mile (640 acres) within the PIAA/DDCT. Monitoring 

results would be reported annually in the Annual Wildlife Monitoring 

Report submitted to the BLM, the NRC, the WDEQ, and the WGFD. Predisturbance surveys would be conducted as required by the appropriate 

regulatory agency. 

The first two conditions were adequately addressed in the PIAA/DDCT 

assessment performed (Appendix D) and, as mentioned in Section 4.9.2, annual 

monitoring and reporting would continue. 

Efforts have been made to meet all stipulations designed for the protection of 

Greater sage-grouse. In the cases of the conflicting aspects (no surface 

disturbance within 0.6 miles of occupied leks and no main roads used to transport 

production and/or waste products located within 1.9 miles of an occupied Greater 

sage-grouse lek), consideration on the part of the WGFD supported exemption 

from these stipulations in the specific case of the Project, as the current road 

layout is anticipated to create less disturbance than if new roads meeting these 

stipulations were required. Therefore, though these specific aspects of the Project 

may impact Greater sage-grouse leks near the Permit Area, the currently proposed 

approach is considered to cause the least impact. Furthermore, annual monitoring 

and reporting would occur in order to adequately track the presence and 

productivity of Greater sage-grouse in the Permit Area. 

4.9.5.4 Raptors 

Impacts to raptors during Construction could include loss and/or modification of 

nesting and foraging habitat, nest abandonment and decreased reproductive 

success due to human presence and Construction activities, direct mortality from 

collisions with infrastructure or vehicles, and reduction in prey populations. 

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Several species of raptors have been observed in the Permit Area including: 

Swainson’s hawk, red-tailed hawk, northern harrier, golden eagle, kestrel, prairie 

falcon, turkey vulture, and ferruginous hawk. The bald eagle occurs only as a 

sporadic migrant and only forages on-site occasionally. The nearest known bald 

eagle nest to the Permit Area is more than five miles away from the Permit Area. 

The ferruginous hawk is the only raptor that is known to nest within the Permit 

Area; there are currently no active nests within the Permit Area (Section 3.8.3.3). 

Ferruginous hawks have been shown to be sensitive to human disturbance, 

especially during periods of courtship, nest building, incubation, and brood 

rearing (Collins and Reynolds, 2005). Nest abandonment and loss of eggs or 

fledglings could occur with human disturbance during the early nesting period. 

These adverse effects could occur with an increase in land-disturbing activities, 

such as road and building construction as well as increased traffic. As discussed 

in Section 4.9.1.9, it is recommended by the USFWS, Wyoming Ecological 

Services Field Office that, for the protection of raptors in general and ferruginous 

hawks particularly, there should be a spatial buffer of one mile around any nest, in 

which no temporary or permanent surface occupancy should occur. As shown in 

Table 4.9-1, disturbance within a one-mile nest buffer would be avoided from 

February 1 to July 31. 

Based on 2011 nesting raptor surveys, one active raptor nest (AFH25921004) was 

found within the one-mile buffer zone, and three active nests were just outside the 

one-mile buffer. Nest AFH25921004 is occupied by a pair of ferruginous hawks 

annually. Two of the active ferruginous hawk nests are on artificial nest 

platforms, and one newly inhabited nest was found on a transmission line 

pole/nest platform adjacent to the existing transmission line (FH24930201). Nest 

FH25921601 was inactive on multiple visits in 2006 through 2011 and was 

observed to be in very poor condition. During the spring of 2012, the BLM’s 

field survey concluded that this nest is now considered historic. An additional 

active ferruginous hawk nest was found during 2011 BLM field surveys. This 

nest is located on the western border of the Permit Area. Figure 4.9-3 shows the 

status of the nests sited in 2011 in the Permit Area and in or near the one-mile 

buffer zone. 

As is shown in Figure 4.9-3, the one-mile buffer around nest AFH25921004 only 

intersects the Permit Area boundary at the northeast corner. No construction 

activity is expected to occur in this area. The new nest found in 2011 is located in 

the path of an existing transmission line and two-track road. A UIC Class I Well 

located about 2,010 feet southeast of this nest was installed as a test well in 2010. 

A pipeline from this well is planned to be constructed along the existing road. 

However, the location of the pipeline was chosen in order to minimize 

disturbance in previously undisturbed areas. The seasonal activity restriction (as 

described in Section 2.1.6.4) would be met for the construction of the pipeline. A 

new transmission line would be constructed that connects to the pre-existing 

powerline running along the western boundary of the Permit Area; however, this 

is not near any active nests (Figure 4.9-3). Overhead transmission lines could 

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impact raptors by encouraging perching and nesting on these lines. As discussed 

in Section 4.9.1, appropriate anti-perching and anti-roosting devices would be 

placed on power poles and cross-arms to discourage roosting by raptors. Tertiary 

transmission lines would be buried in order to minimize risks to raptors and large 

birds. In cases where transmission line burial were not an option, overhead lines 

would be constructed to current standards using publications such as those from 

the Avian Power Line Interaction Committee (2006). This would include crossarm and transformer design. This design would minimize potential mortality due 

to electrocution. Furthermore, this nest was a stick nest built in the cross-arms of 

a transmission pole. This nest blew down sometime during the fall of 2011 and is 

no longer present (Berg, E. LWR Consultants, Inc., Senior Project 

Manager/Wildlife Biologist. Personal communication. 2012). 

As discussed above, only approximately two percent of the Permit Area would be 

disturbed during Construction. Therefore, raptor prey populations are not 

anticipated to be affected due to the low percentage of habitat disturbance in the 

Permit Area and the contiguous, suitable prey habitat outside of the Permit Area. 

As of the time of publication, the NRC SEIS reported that there are no active 

nests in the Permit area, and as a result, impacts to raptors are expected to be 

minimal (NRC, 2011a). 

4.9.5.5 Waterfowl and Shorebirds 

Just two waterfowl species (mallard, Canada goose) have been observed during 

bird and wildlife surveys. Waterfowl and shorebird use of the Permit Area is very 

limited. Wetlands, ponds, riparian zones and other potential waterfowl and 

waterbird habitat are almost nonexistent. No significant impacts are expected for 

these birds during the Construction phase. 

The NRC SEIS (Section 4.6.1.1.1.2) states that due to the lack of surface water in 

the region, the habitat is not suitable for important functions of the few waterfowl 

and shorebird species found in the area. Any impact would be insignificant 

(NRC, 2011a). 

4.9.5.6 Migratory Birds of High Federal Interest 

Level I MBHFI species documented in the Permit Area were the ferruginous 

hawk, Greater sage-grouse, Brewer’s sparrow, and sage sparrow. The mountain 

plover and burrowing owl have been noted in adjacent areas. Level II species 

documented in the Permit Area include the sage thrasher, loggerhead shrike, 

vesper sparrow, and lark sparrow (Section 3.8.3.6). 

Anticipated impacts to the ferruginous hawk were previously discussed in this 

section, as were Greater sage-grouse impacts. Potential impacts to other MBHFI 

species include loss of habitat, displacement due to human activities, and 

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mortality due to vehicle collisions. The breeding Brewer’s sparrow and sage 

sparrow were found throughout the Big Sagebrush Shrubland habitats of the 

Permit Area. Breeding sage thrasher, loggerhead shrike, vesper sparrow, and lark 

sparrow were also located within the Permit Area. Lowland Big Sagebrush 

Shrubland vegetation provided the greatest species diversity for MBHFI species 

use. Only a small portion of this habitat would be disturbed (less than one percent 

of the Permit Area during Construction), and, where possible, Project activities 

would be located outside of this habitat type. Therefore, population level effects 

due to habitat loss for MBHFI species are not expected. 

Good potential mountain plover nesting habitat is not present in the Permit Area 

and no mountain plover have been observed on-site during extensive field studies. 

Therefore, it is unlikely that mountain plovers nest within the Permit Area. 

Section 4.6.1.1.1.2 of the NRC SEIS discusses the impacts to migratory birds, 

both direct and indirect. Direct impacts include vehicle collisions and increased 

human activity, which may deter birds from the Permit Area. Indirect impacts 

include loss of habitat and displacement of birds. While these impacts may affect 

a few individuals, there would likely be no significant impact on an entire species 

due to the small Permit Area relative to the surrounding region (NRC, 2011a). 

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4.9.5.7 Threatened and Endangered Species 

Federally Listed or Candidate Species 

No federally or state listed sensitive species, T&E species, or designated critical 

habitats occur in the Permit Area; therefore, no adverse impacts from 

Construction or any other phase of the Project are anticipated. The bald eagle 

(formerly listed as threatened, currently delisted) and black-footed ferret 

(endangered) are the only federally listed, previously listed, or candidate wildlife 

species that may potentially occur in the local vicinity (USFWS, 2008). The bald 

eagle may occur as a sporadic migrant, and may forage on-site occasionally. The 

nearest known bald eagle nest to the Permit Area is more than five miles away. 

The black-footed ferret is found in active prairie dog colonies. However, there 

are no active white-tailed prairie dog colonies in the Permit Area and the nearest 

active prairie dog colonies are one to two miles south and southwest of the Permit 

Area. Therefore, no impacts are anticipated to the black-footed ferret or the bald 

eagle. A Biological Assessment was prepared in accordance with legal 

requirements set forth under Section 7 of the Endangered Species Act (16 USC 

1536 (c)), and following the recommended USFWS guidelines (Appendix G). 

As agreed upon by the USFWS, the assessment resulted in a determination of no 

effect to threatened, endangered or proposed species. 

BLM Special Status Species 

Pygmy Rabbits 

One species of concern that may be uniquely impacted is the Pygmy rabbit, which 

has a preferred habitat limited to the Lowland Big Sagebrush Shrubland (Section 

3.8.3.8). Construction of infrastructure in the Lowland Big Sagebrush Shrubland 

may result in a decrease in available and suitable habitat within the Permit Area. 

However, Project facilities and activities would be limited on the Lowland Big 

Sagebrush Shrubland and avoided when possible (approximately one percent 

disturbance of this habitat type is expected to occur in the Permit Area during 

Construction). Limited direct mortality of Pygmy rabbits would be expected 

where Project activities disturb the Lowland Big Sagebrush Shrubland habitat. 

The overall impact to the Pygmy rabbit population in the area is expected to be 

minimal due to the relative small area of disturbance and the proposed protection 

measures discussed in Section 4.9.1. 

The NRC SEIS states in Section 4.6.1.1.1.5 that a few individual Pygmy rabbits, 

due to their burrowing habits in and near the construction site, could be lost 

during the Construction phase. However, since there is a large area of untouched 

habitat, the impacts to the species as a whole would be small (NRC, 2011a). 

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Wyoming Pocket Gophers 

Project Construction would result in long-term direct impacts to the Wyoming 

pocket gophers within the Permit Area. Wyoming pocket gopher active burrow 

complexes were located throughout the Permit Area (Section 3.8.3.8). Burrow 

complexes were located within very small open and grassy pockets within the 

Upland Big Sagebrush Shrubland habitat. Project Construction would result in 

ground and vegetation disturbances, ground compaction, and fragmentation of 

sagebrush habitat. At most, eight percent of vegetation within the Permit Area 

would be disturbed during Construction. Wyoming pocket gopher burrow 

complexes can be expected to disappear in the disturbed areas for the life of the 

Project and direct mortalities from construction equipment can also be expected. 

Because of the very similar surrounding habitat conditions, Wyoming pocket 

gophers are expected to exist throughout the Permit Area and outside the Permit 

Area; thus, a population-level effect is not expected for the surrounding areas. It 

is also possible that Wyoming pocket gophers would recolonize the Permit Area 

after Reclamation. 

4.9.5.8 Reptiles and Amphibians 

Reptiles observed during general surveys included the greater short-horned lizard, 

prairie rattlesnake, and western terrestrial garter snake. No amphibians were 

observed within the Permit Area. No Great Basin spadefoot toad vocalizations 

were heard during auditory surveys completed for this species during the spring 

and early summer of 2010 and 2011. This species is not thought in be present in 

the Permit Area (Section 3.8.3.9). 

Potential impacts to reptiles and amphibians during Construction would include 

habitat loss or alteration, incremental habitat fragmentation, and direct and/or 

indirect mortalities. Since only a small percent of the total Permit Area would be 

disturbed, herpetofauna are expected to disperse somewhat from the disturbed 

areas within the Permit Area as Construction activities approach, minimizing the 

occurrence of direct casualties. However, direct mortality could occur due to 

vehicle traffic or equipment use. These direct casualties are not expected to have 

a population-level effect. 

4.9.6 Operation 

The Operation phase includes ISR of uranium from the mine units and subsequent 

processing in the Plant. 

4.9.6.1 General Impacts on Wildlife 

The primary Operational impacts on wildlife are displacement/stress to wildlife 

from human activity and direct and/or indirect mortalities. There is also a 

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potential for exposure to spills containing trace quantities of toxic chemicals 

during the Operation phase. Habitat alteration and incremental habitat 

fragmentation are expected to be minimal as no additional habitat disturbance 

would occur (Section 4.8). 

During Operation, spills around wellheads and leaks from pipelines could expose 

wildlife to trace quantities of toxic chemicals. LCI's leak detection systems and 

SPCC plan to remove affected soils and capture release fluids would reduce 

impacts. If spills or leaks were handled using BMPs, impacts to wildlife would be 

minimal. 

Wildlife use of areas adjacent to ISR operations is anticipated to increase as 

animals become habituated to the activity. Because wildlife may be in proximity 

to Project buildings, roads, and mine units, some impacts to wildlife would be 

expected to occur from direct conflict with vehicular traffic and the presence of 

on-site personnel. Traffic volume during the Operation phase would likely be on 

the same order as for Construction; however, there would be less transport of 

heavy equipment and more transport of wastes and yellowcake slurry off-site 

(Section 4.3). These activities could reduce species use within the Permit Area, 

resulting in a concentration of species in the surrounding habitat. Increased 

predation and competition for forage may also occur. Noise from Operation 

activities is expected to be less than that generated from Construction activities 

(Section 4.12). Also, considering the size of the comparable surrounding habitat, 

these impacts would be minimal because they would affect only a few individuals 

and would not threaten the continued existence of any particular species in the 

Permit Area. 

4.9.6.2 Big Game 

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

Increases in mortality from motor vehicle collisions are expected to remain at a 

minor level during Operation. Additional impacts during Operation include the 

potential for exposure to spills containing trace quantities of toxic chemicals 

during incidental spills, and avoidance of the Permit Area due to human activity. 

However, the potential for these impacts would be minimized due to protective 

efforts discussed in Section 4.9.1. 

The NRC SEIS states in Section 4.6.1.2.2 that the Operation phase would have 

fewer impacts than the Construction phase on big game in the Permit Area (NRC, 

2011a). 

4.9.6.3 Greater Sage-Grouse 

Potential impacts to Greater sage-grouse during Operation could include 

increased disturbances due to human presence and Operation activities and direct 

mortality from fencing and the Storage Ponds. 

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

Potential impacts to Greater sage-grouse during all phases of the Project from 

surface disturbance, seasonal timing, transportation, noise, and other disturbances 

were assessed in accordance with the SGIT stipulations (Mead, 2011 and 

Wyoming Interagency, 2011), and were previously discussed. 

Fences used to restrict cattle and wild horses from entering the mine unit pattern 

areas would not restrict Greater sage-grouse. Cattle may, however, be displaced 

to adjacent lands shared by Greater sage-grouse. Cattle graze on grasses and 

forbs that provide crucial nesting and brooding habitat for the birds. An increased 

concentration of both Greater sage-grouse and cattle may cause adverse effects to 

habitat (Perry, 2010). However, considering few cattle would be displaced by the 

Project (Section 4.2.4.1) and the large amount of analogous habitat surrounding 

the Permit Area, the potential impact from shifts in grazing patterns is low. 

Fences installed around the pattern areas of the mine units (Section 2.1.2.6) could 

pose a direct adverse effect to Greater sage-grouse because collisions have been 

anecdotally reported to cause injury and mortality. After the WGFD conducted a 

study on this matter, it was found that the highest risk fences are those that: are 

constructed with steel t-posts; are constructed near leks; bisect winter 

concentration areas; and/or border riparian areas (Christiansen, 2009). The fences 

would not be within a quarter mile of the leks nor would they be adjacent to 

riparian areas. Wintering Greater sage-grouse prefer dense sagebrush stands that 

extend above snow cover and provide escape and thermal cover to the birds. 

Locations from 30 individual radio-equipped females were documented during the 

winter of 2010; however, no detailed on-the-ground surveys for winter Greater 

sage-grouse use have been completed in the Permit Area. Based on habitat 

conditions, the Lowland Big Sagebrush Shrubland habitat areas likely provide 

important Greater sage-grouse winter habitat (Naugle et al., 2006; WGFD, 2003). 

As discussed in Sections 4.9.1.2 and 4.9.1.10, in order to mitigate Greater sagegrouse collisions with fences, fence markers would be installed on new fence 

lines to increase the visibility of the lines. New fences would also be monitored 

for evidence of Greater sage-grouse strikes. 

Fences may also be a hazard to Greater sage-grouse because they offer potential 

raptor perches, which may increase predation. As discussed in Section 4.9.1.2, 

anti-perch measures on fence lines would be taken to reduce excessive predation 

of Greater sage-grouse. Fences would be used around the Storage Ponds (Section 

2.1.2.6). If Greater sage-grouse were to use the Storage Ponds as a regular water 

source, there would be an exposure potential. However, the amount of freeboard 

and water depth maintained for the two ponds should make it difficult for Greater 

sage-grouse to drink from the ponds. Hazards associated with the quality of the 

water in the Storage Ponds along with protection efforts are discussed in detail 

below in the section discussing waterfowl and shorebird impacts. The Storage 

Ponds would be designed to minimize access to all wildlife, including Greater 

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sage-grouse. The Storage Ponds would be monitored daily for wildlife mortality. 

If evidence of mortality were present, additional measures may be taken to 

prevent access. 

The NRC SEIS states in Section 4.6.1.2.2 that the Operation phase could disrupt 

the reproductive stage of Greater sage-grouse nesting near the Project 

infrastructure. This could have some localized significant impacts to Greater 

sage-grouse, but would likely not affect the entire population in the region (NRC, 

2011a). 

4.9.6.4 Raptors 

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

Noise associated with traffic and the potential for mortalities from collisions with 

vehicles or overhead lines would remain potential adverse effects. As discussed 

in Section 4.9.1, overhead transmission lines would have anti-perch devices. 

Header houses, fences, well heads and other operational infrastructure would also 

employ anti-perch technology to minimize damage to facilities and ensure the 

health and safety of the raptors. 

During Operation, routine maintenance of the UIC Class I well located southeast 

of the nest found by the BLM in 2011 would be necessary and would require 

minimal traffic on the existing two-track road. This disturbance may have an 

impact on the proximal nest if it were rebuilt in the same location in future years. 

The NRC SEIS states in Section 4.6.1.2.2 that the Operation phase could disrupt 

the reproductive stage of raptors nesting near the Project infrastructure. This 

could have some significant impacts to raptors, but would likely not affect the 

entire population in the region (NRC, 2011a). 

4.9.6.5 Waterfowl and Shorebirds 

The only fluid-holding structures would be the Storage Ponds, which would be 

used during the Operation phase to temporarily store the water that would 

ultimately be disposed of in the UIC Class I wells. The Storage Ponds are 

described in detail in Section OP 2.9.4 of the WDEQ-LQD Permit to Mine (LCI, 

2011b). The Storage Ponds would be fenced to prevent access by wildlife on the 

ground and for safety reasons (Section 2.1.2.6). Based on the anticipated poor 

quality of the water in the Storage Ponds ( 

Table 4.9-2), fencing and deterrents would be used to prevent waterfowl from 

inhabiting the ponds and becoming exposed via ingestion. If local sagebrush 

endemic passerine bird species were to use the Storage Ponds as a regular water 

source, there would be an exposure potential. The three feet of freeboard and 

water depth maintained for the two Storage Ponds should make it difficult for 

land birds (such as Greater sage-grouse), passerine birds, and wading birds (such 

as herons) to drink from the Storage Ponds. An exception might be swallows, if 

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present in the area, that drink water on the wing. Waterfowl are not expected to 

reside on the Storage Ponds for more than a few days. A study of waste water 

ponds in central Idaho noted that waterfowl resided from one to 25 days, with an 

average residence time at the ponds of six days (Halford et al., 1982). 

As described in detail in Section OP 2.9.4 of the WDEQ-LQD Permit to Mine 

(LCI, 2011a), the water quality of the Storage Ponds would be checked quarterly 

to ensure that unanticipated changes in the water quality were detected, and would 

also be checked whenever a process change may result in a significant change in 

water quality. An estimation of the water quality of the Storage Ponds is provided 

in Table 4.9-2, below. The estimated concentrations of selenium range from 0.01 

to 0.2 mg/L. Skorupa and Ohlendorf (1991) reported that exposures to water with 

selenium concentrations of 20 ppb (20 μg/L or 0.02 mg/L) and higher can be 

widely hazardous to aquatic birds. Therefore, as noted in Section OP 5.2.3.1 of 

the WDEQ-LQD Permit to Mine (LCI, 2011b), the concentration of selenium 

would kept at a level less than or equal to 0.02 mg/L. Because even lower levels 

of selenium in water have the potential to create toxic effects in waterfowl 

through bioaccumulation (Skorupa and Ohlendorf 1991; Lemly 1993; and 

Hamilton 2002), the growth of algae and plankton would be monitored, and if 

necessary, an herbicide, approved for use in pond settings, would be used to 

reduce or eliminate such growth, thereby reducing the potential for 

bioaccumulation of selenium. The ecological risks of herbicide application would 

be assessed prior to treatment of the Storage Ponds. The BLM would require the 

applicant to obtain a Pesticide Use Proposal with associated environmental 

analysis and consider other Integrated Pest Management techniques, prior to 

authorizing the use of pesticides. Analysis of selenium concentrations in algae, 

submerged aquatic vegetation, and/or aquatic invertebrates present in the Storage 

Ponds may provide data useful in determining the need for herbicide application. 

The dietary threshold for selenium is 3 μg/g dry weight for sensitive species of 

aquatic birds (Lemly 1993). 

The location of the Storage Ponds adjacent to the Plant, and associated human 

activity (including daily checks of the Storage Ponds), is anticipated to reduce the 

attractiveness of the Storage Ponds to wildlife. Deterrents, such as flagging and 

predator silhouettes or decoys, would also be used. If the level of selenium in the 

Storage Ponds cannot be maintained at a level of less than or equal to 0.02 mg/L 

selenium, mitigation measures would be put in place to prevent birds from 

accessing the Storage Ponds. Mitigation measures applied would be approved by 

the BLM and the efficiency of the mitigation applied would be monitored. Safe 

limits for birds for other constituents were explored and discussed in detail in the 

WDEQ-LQD Permit to Mine (LCI, 2011b). Briefly, Maximum Threshold Limits 

(MTLs) for poultry regarding aluminum, arsenic, fluoride, manganese, selenium, 

and vanadium are equal to or greater than the anticipated maximum 

concentrations for these analytes in the Storage Ponds ( 

Table 4.9-2). 

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Table 4.9-2 Estimated Water Quality of the Storage Ponds 

Analyte Estimated Range (mg/L) 

Major Constituents Low High 

Aluminum ND 0.2 

Ammonia as Nitrogen ND 4 

Bicarbonate as HCO3 1,200 2,500 

Calcium 50 300 

Carbonate as CO3 ND 25 

Chloride 200 1,000 

Magnesium 4 50 

pH 7 9 

Potassium 10 200 

Ra-226 (pCi/L) 200 1,500 

Silica 14 20 

Sodium 150 2,000 

Sulfate 50 500 

TDS 1,600 6,500 

Uranium as U3O8 1 15 

Trace Parameters Low High 

Arsenic 0.002 0.020 

Barium ND ND 

Boron ND ND 

Cadmium ND ND 

Chromium ND ND 

Copper ND ND 

Fluoride 0.2 0.5 

Lead ND ND 

Manganese 0.04 0.5 

Mercury ND ND 

Molybdenum ND ND 

Nickel ND ND 

Selenium 0.01 0.2 

Vanadium ND 0.01 

4.9.6.6 Migratory Birds of High Federal Interest 

As discussed before, the Lowland Big Sagebrush Shrubland vegetation was found 

to provide the greatest species diversity for MBHFI species use. During the 

Operation phase, there would be little, if any, new habitat disturbance. Migratory 

birds and other wildlife could be affected by exposure to constituents in the 

Storage Ponds, but perimeter fencing and netting would limit impacts. Therefore, 

population level effects due to habitat loss or increased competition are not 

expected for MBHFI species. 

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The NRC SEIS discusses that migratory birds could be exposed to toxic 

chemicals in the Storage Ponds. However, the protection measures put in place 

would limit their interaction with this water and result in minimal impacts (NRC, 

2011a). 

4.9.6.7 Threatened and Endangered Species 

Federally Listed or Candidate Species 

No federally or state listed sensitive species, T&E species, or designated critical 

habitats occur within the Permit Area; therefore, no adverse impacts from 

Operation or any other phase of the Project are anticipated. 

The NRC SEIS also makes this comment that the lack of these species eliminates 

the potential impacts (NRC, 2011a). 

BLM Special Status Species 

Pygmy Rabbits 

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

The overall impact to Pygmy rabbit populations in the area is expected to be 

minimal due to the limited number of individuals affected, the relatively small 

area of disturbance, and the proposed protection measures. 

Wyoming Pocket Gophers 

Impacts to Wyoming pocket gophers would be smaller during the Operation 

phase to those in the Construction phase. During the Operation phase, there 

would be little, if any, new habitat disturbance. Ongoing activities during the 

Operation phase would continue to make site conditions unfavorable for 

recolonization of Wyoming pocket gophers. However, undisturbed areas in the 

Permit Area and areas outside the Permit Area with similar habitat type may still 

support Wyoming pocket gophers; therefore, a population-level effect is not 

predicted. 

4.9.6.8 Reptiles and Amphibians 

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

The overall impact to reptile and amphibian populations in the area is expected to 

be minimal due to the relatively small area of disturbance and the proposed 

protection measures described in Section 4.9.1. 

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4.9.7 Reclamation 

4.9.7.1 General Impacts on Wildlife 

Reclamation includes the progressive Mine Unit Restoration and Reclamation 

stage and the Final Reclamation stage. During Mine Unit Restoration and 

Reclamation, additional disturbance would occur during some activities, e.g., 

when wells were abandoned and pipelines were removed from reseeded areas. 

However, this ‘re-disturbance’ of the same areas, e.g., a pipeline corridor, is not 

counted twice in the assessment of the acres disturbed. 

There should be no additional habitat acreage disturbance during Reclamation. 

Short-term land disturbance would occur during decommissioning of supporting 

facilities and roads, as soils were excavated, buried piping were recovered and 

removed, and structures were demolished and removed. Revegetation would 

restore habitat previously altered during Construction and Operation. After 

removal of structures, such as the Plant and Storage Ponds, the surface would be 

regraded and topsoil replaced. Disturbed areas would be seeded with native 

vegetation once the buildings were removed. No loss of additional vegetative 

communities is expected beyond those previously disturbed during Construction 

and Operation. The removal of piping would impact vegetation that has reestablished itself, although this, too, would be temporary once the disturbed soil 

were reseeded. Wildlife habituated to the Operation would be temporarily 

displaced, but are expected to return after Reclamation were completed and 

vegetation and habitat were re-established. As the areas were reseeded with the 

permanent seed mix, there could be changes in the proportion of various species, 

including an increase in weeds. This alteration of habitat could potentially affect 

habitat desirability. However, actions would be taken to mitigate weed invasion 

(Section 4.8.1). Overall, impacts would be considerably less for this phase than 

for Construction and Operation. 

Contamination of soils could result from leaks and spills during Reclamation. 

However, detection and response techniques, and eventual survey and treatment 

(if necessary) of all impacted soils and sediments, would limit the magnitude of 

overall impacts to terrestrial wildlife. 

Similar to Construction activities, Reclamation activities are expected to create 

added noise and traffic (in comparison with Operation) as buildings were taken 

down and hauled away. During this time, wildlife could come in conflict with 

heavy equipment, or may move elsewhere on the property to avoid higher-thannormal noise. However, these impacts would be short-term in nature. 

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4.9.7.2 Big Game 

No impacts are expected for mule deer and elk. No additional impacts are 

expected for pronghorn from Reclamation. Furthermore, detrimental impacts 

occurring in past phases would be further minimized as recovered land were 

vegetated to pre-Construction conditions. The fences would be removed after ISR 

operations were complete and vegetation became re-established in accordance 

with permit requirements (Section RP 4.5.4 of the WDEQ-LQD Permit to Mine 

[LCI, 2011a]) unless otherwise approved and agreed upon with the landowner 

(BLM). Increases in mortality from motor vehicle collisions due to increases in 

traffic are expected to remain at a minor level during Reclamation. Additional 

impacts during Reclamation are the potential for exposure to spills containing 

trace quantities of toxic chemicals during incidental spills, and avoidance due to 

human activity. However, protection efforts discussed in Section 4.9.1 would 

minimize risks. 

The NRC SEIS states the impacts to big game species during the Reclamation 

phase would be similar to the impacts suggested in the Construction phase (NRC, 

2011a). 

4.9.7.3 Greater Sage-Grouse 

Short-term impacts to Greater sage-grouse from noise and disturbance during the 

influx in activity from the removal of infrastructure during Reclamation are 

possible. A potential indirect impact from Reclamation is the stripping of topsoil 

and vegetation, which could allow noxious weeds to seed before native grasses 

and sagebrush. Therefore, weed control is an important issue for Reclamation and 

protection of existing habitats for Greater sage-grouse. As discussed in Section 

4.8.1, BLM-approved weed prevention measures, such as prompt reseeding with 

native vegetation, cleaning of equipment, and minimizing soil disturbance, would 

be implemented. 

The NRC SEIS reports that Greater sage-grouse impacts during the Reclamation 

phase could be significant in the short-term. After reseeding and reclaiming the 

land to a functioning ecosystem, the impacts would be significantly reduced 

(NRC, 2011a). 

4.9.7.4 Raptors 

No additional acres would be disturbed during Reclamation for the removal and 

decommissioning of Project infrastructure beyond those impacted in Operation 

and Construction. If the BLM and other land owners were to agree to retain any 

upgraded roads associated with the Project after Reclamation, there may be 

potential long-term impacts to raptors from the road and associated traffic. 

However, all other Project-related facilities would be removed and the preexisting 

state of the landscape would be, at a minimum, reclaimed and likely enhanced; 

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therefore, adverse effects to raptors during the Reclamation phase are expected to 

be negligible. 

The NRC SEIS states the impacts to raptors during the Reclamation phase would 

be similar to the impacts identified for the Construction phase (NRC, 2011a). 

4.9.7.5 Waterfowl and Shorebirds 

No further impacts to this group are expected during Reclamation. 

4.9.7.6 Migratory Birds of High Federal Interest 

Impacts to MBHFI species are expected to be similar in the Reclamation phase as 

in the Construction phase. However, effects would be minimized as recovered 

land is vegetated to pre-Construction conditions. 

4.9.7.7 Threatened and Endangered Species 

Federally Listed or Candidate Species 

No federally or state listed sensitive species, endangered or threatened species, or 

designated critical habitats occur within the Permit Area; therefore, no adverse 

impacts from Reclamation or any other phase of the Project are anticipated. 

The NRC SEIS also states that the lack of these species eliminates the potential 

impacts (NRC, 2011a). 

BLM Special Status Species 

Pygmy Rabbits 

Impacts to Pygmy rabbits during Reclamation would be short-term habitat 

disturbance, which would occur as structures were demolished and removed and 

the ground surface were recontoured. Upon completion of decommissioning, 

revegetation, and recontouring, habitat would be re-established. 

Wyoming Pocket Gophers 

Impacts would be limited during Reclamation. Based on surrounding habitat 

conditions, and the fact that Wyoming pocket gophers were captured throughout 

the areas that would be disturbed during Construction and Operation, it is 

expected that Wyoming pocket gophers are present in appropriate habitats within 

the larger Permit Area, and also surrounding areas. Re-colonization from 

surrounding, undisturbed areas may occur if habitat conditions following the 

Reclamation phase provided adequate soil and vegetation conditions. Loss of the 

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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

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Wyoming pocket gopher population within the disturbed area would not impact 

local populations and would not cause a trend towards Federal listing of the 

species. 

4.9.7.8 Reptiles and Amphibians 

Impacts to reptiles and amphibians are expected to be similar in the Reclamation 

phase as in the Construction phase. However, effects would be minimized as land 

were vegetated to pre-Construction conditions. 

4.9.8 Wildlife Impacts from Other Alternatives 

4.9.8.1 No Action Alternative 

Under the No Action Alternative, there would be no ISR facility construction 

associated with the Project, and therefore no habitat disturbance associated with 

Construction, Operation, and Reclamation would occur. The area would continue 

to provide vegetation communities and wildlife habitat typical of the region. 

Land would continue to be used for rangeland; and grazing leases would continue. 

Impacts from other existing activities, such as grazing, mineral exploration, 

recreation and hunting would continue. 

4.9.8.2 Not Fencing the Pattern Areas 

There would be a slight reduction in the acres of vegetation and habitat 

disturbance if the fences around the patterns areas were not constructed. 

However, the protection measures in the pattern areas, specifically reseeding, 

would be adversely impacted as the new vegetation growth in the reseeded areas 

would be preferred by livestock and wild horses. Also, collisions of wildlife with 

fences and increased predation due to perching on fences would not occur. 

4.9.8.3 Drying Yellowcake On-site 

This alternative would have minimal additional impacts on habitat resources at 

the Permit Area, as the dryer would be within the Plant. Since a vacuum dryer 

would be installed, impacts to wildlife in the Permit Area from toxic emissions 

would not be expected. There would be an added potential for harmful leaks to 

occur; however, this potential would be mitigated through proper operational 

precautions and risk management. 

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